December 2024
United States Office of Chemical Safety and
v/trM Environmental Protection Agency Pollution Prevention
Occupational Exposure Assessment for Formaldehyde
CASRN 50-00-0
A
December 2024
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TABLE OF CONTENTS
EXECUTIVE SUMMARY 16
1 INTRODUCTION 18
1.1 Changes between Draft and Revised Assessment 18
1.2 Scope 19
2 APPROACH AND METHODOLOGY 28
2.1 Approach and Methodology for Process Descriptions 29
2.2 Approach and Methodology for Estimating Number of Facilities 29
2.3 Identifying Worker Activities 30
2.4 Estimating Number of Workers and Occupational Non-users 30
2.5 Inhalation Exposure Approaches 31
2.5.1 Inhalation Monitoring Data 31
2.5.2 Inhalation Exposure Modeling 34
2.6 Dermal Exposure Approach 34
2.7 Evidence Integration for Occupational Exposure 35
3 OCCUPATIONAL EXPOSURE ASSESSMENT 37
3.1 Manufacturing - Domestic Manufacturing 37
3.1.1 Manufacturing of Formaldehyde 37
3.1.1.1 Process Description 37
3.1.1.2 Worker Activities 39
3.1.1.3 Inhalation Exposure Estimates 39
3.1.1.4 Dermal Exposure Estimates 41
3.2 Manufacturing - Importing 41
3.2.1 Import and/or Repackaging of Formaldehyde 41
3.2.1.1 Process Description 41
3.2.1.2 Worker Activities 42
3.2.1.3 Inhalation Exposure Estimates 43
3.2.1.4 Dermal Exposure Estimates 43
3.3 Processing - Reactant - [All Functions] in [All Industries] 44
3.3.1 Processing as a Reactant 44
3.3.1.1 Process Description 44
3.3.1.2 Worker Activities 46
3.3.1.3 Inhalation Exposure Estimates 46
3.3.1.4 Dermal Exposure Estimates 50
3.4 Processing - Incorporation into an Article - Finishing Agents in Textile, Apparel, and
Leather Manufacturing 50
3.4.1 Textile Finishing 51
3.4.1.1 Process Description 51
3.4.1.2 Worker Activities 52
3.4.1.3 Inhalation Exposure Estimates 52
3.4.1.4 Dermal Exposure Estimates 54
3.5 Processing - Incorporation into an Article - Paint Additives and Coating Additives Not
Described by Other Categories in Transportation Equipment Manufacturing 54
3.5.1 Use of Coatings, Paints, Adhesives, or Sealants 54
3.5.1.1 Process Description 54
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3.5.1.2 Worker Activities 58
3.5.1.3 Inhalation Exposure Estimates (Spray or Unknown Application) 59
3.5.1.4 Inhalation Exposure Estimates (Non-spray applications) 60
3.5.1.5 Dermal Exposure Estimates 61
3.6 Processing - Incorporation into an Article - Additive in Rubber Product Manufacturing 62
3.6.1 Rubber Product Manufacturing 62
3.6.1.1 Process Description 62
3.6.1.2 Worker Activities 63
3.6.1.3 Inhalation Exposure Estimates 63
3.6.1.4 Dermal Exposure Estimates 65
3.7 Processing - Incorporation into Article - Adhesives and Sealant Chemicals in Wood Product
Manufacturing; Plastic Material and Resin Manufacturing (Including Structural and
Fireworthy Aerospace Interiors); Construction (Including Roofing Materials); Paper
Manufacturing 65
3.7.1 Composite Wood Product Manufacturing 66
3.7.1.1 Process Description 66
3.7.1.2 Worker Activities 66
3.7.1.3 Inhalation Exposure Estimates 66
3.7.1.4 Dermal Exposure Estimates 68
3.7.2 Other Composite Material Manufacturing 68
3.7.2.1 Process Description 68
3.7.2.2 Worker Activities 69
3.7.2.3 Inhalation Exposure Estimates 69
3.7.2.4 Dermal Exposure Estimates 70
3.7.3 Paper Manufacturing 71
3.7.3.1 Process Description 71
3.7.3.2 Worker Activities 71
3.7.3.3 Inhalation Exposure Estimates 71
3.7.3.4 Dermal Exposure Estimates 72
3.7.4 Plastic Product Manufacturing 73
3.7.4.1 Process Description 73
3.7.4.2 Worker Activities 73
3.7.4.3 Inhalation Exposure Estimates 73
3.8 Processing - Incorporation into a Formulation, Mixture, or Reaction Products - [All
Functions] in [All Industries] 75
3.8.1 Processing of Formaldehyde into Formulations, Mixtures, or Reaction Products 76
3.8.1.1 Process Description 76
3.8.1.2 Worker Activities 77
3.8.1.3 Inhalation Exposure Estimates 77
3.8.1.4 Dermal Exposure Estimates 79
3.9 Processing-Repackaging- Sales to distributors for laboratory chemicals 79
3.10 Processing-Recycling 79
3.10.1 Recycling 79
3.10.1.1 Process Description 79
3.10.1.2 Worker Activities 80
3.10.1.3 Inhalation Exposure Estimates 80
3.10.1.4 Dermal Exposure Estimates 81
3.11 Distribution in Commerce 81
3.11.1 Storage and Retail Stores 81
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3.11.1.1 Process Description 81
3.11.1.2 Worker Activities 82
3.11.1.3 Inhalation Exposure Results 82
3.12 Industrial Use - Non-incorporative Activities - Used in: Construction 83
3,12,1 Furniture Manufacturing 83
3.12.1.1 Process Description 83
3.12.1.2 Worker Activities 84
3.12.1.3 Inhalation Exposure Estimates 84
3.12.1.4 Dermal Exposure Results 85
3.13 Industrial Use - Non-incorporative Activities - Oxidizing/Reducing Agent, Processing Aids,
Not Otherwise Listed 86
3.13.1 Processing Aid 86
3.13.1.1 Process Description 86
3.13.1.2 Worker Activities 86
3.13.1.3 Inhalation Exposure Estimates 86
3.13.1.4 Dermal Exposure Estimates 87
3.14 Industrial Use - Non-incorporative Activities - Process Aid in: Oil and Gas Drilling,
Extraction, and Support Activities; Process Aid Specific to Petroleum Production, Hydraulic
Fracturing 87
3.14.1 Use of Formaldehyde for Oilfield Well Production 87
3.14.1.1 Process Description 87
3.14.1.2 Worker Activities 89
3.14.1.3 Inhalation Exposure Estimates 89
3.14.1.4 Dermal Exposure Estimates 91
3.15 Industrial Use - Chemical Substances in Industrial Products - Paints and Coatings;
Adhesives and Sealants; Lubricants 91
3.15.1 Industrial Use of Lubricants 91
3.15.1.1 Process Description 91
3.15.1.2 Worker Activities 92
3.15.1.3 Inhalation Exposure Estimates 92
3.15.1.4 Dermal Exposure Estimates 93
3.15.2 Foundries 93
3.15.2.1 Process Description 93
3.15.2.2 Worker Activities 94
3.15.2.3 Inhalation Exposure Estimates 94
3.15.2.4 Dermal Exposure Estimates 95
3.16 Commercial Use - Chemical Substances in Furnishings Treatment/Care Products - Floor
Coverings; Foam Seating and Bedding Products; Furniture and 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 95
3.16.1 Installation and Demolition of Formaldehyde-Based Furnishings and
Building/Construction Materials in Residential, Public and Commercial Buildings, and
Other Structures 96
3.16.1.1 Process Description 96
3.16.1.2 Worker Activities 96
3.16.1.3 Inhalation Exposure Estimates 97
3.16.1.4 Weight of Scientific Evidence in Inhalation Exposure Estimates 98
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3.16.1.5 Dermal Exposure Estimates 99
3.17 Commercial Use - Chemical Substances in Treatment Products - Water Treatment Products . 99
3,17.1 Use of Formulations containing Formaldehyde for Water Treatment 99
3.17.1.1 Process Description 99
3.17.1.2 Worker Activities 99
3.17.1.3 Inhalation Exposure Estimates 99
3.17.1.4 Dermal Exposure Estimates 100
3.18 Commercial Use - Chemical Substances in Treatment/Care Products -Laundry and
Dishwashing Products 100
3.18.1 Use of Formulations Containing Formaldehyde in Laundry and Dishwashing Products ... 100
3.18.1.1 Process Description 100
3.18.1.2 Worker Activities 101
3.18.1.3 Inhalation Exposure Estimates 101
3.18.1.4 Dermal Exposure Results 102
3.19 Commercial Use - Chemical Substances in Construction, Paint, Electrical, and Metal
Products - Adhesives and Sealants; Paints and Coatings 102
3.20 Commercial Use - Chemical Substances in 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 103
3.21 Commercial Use - Chemical Substances in Electrical Products - Machinery, Mechanical
Appliances, Electrical/Electronic Articles; Other Machinery, Mechanical Appliances,
Electronic/Electronic Articles 103
3.21.1 Use of Electronic and Metal Products 103
3.21.1.1 Process Description 103
3.21.1.2 Worker Activities 103
3.21.1.3 Inhalation Exposure Estimates 103
3.21.1.4 Dermal Exposure Estimates 104
3.22 Commercial Use - Chemical Substances in Metal Products - Construction and Building
Materials Covering Large Surface Areas, Including Metal Articles 105
3.23 Commercial Use - Chemical Substances in Automotive and Fuel Products - Automotive
Care Products; Lubricants and Greases; Fuels and Related Products 105
3.23.1 Use of Formulations Containing Formaldehyde in Automotive Care Products 105
3.23.1.1 Process Descriptions 105
3.23.1.2 Worker Activities 105
3.23.1.3 Inhalation Exposure Estimates 105
3.23.1.4 Dermal Exposure Estimates 107
3.23.2 Use of Automotive Lubricants 107
3.23.2.1 Process Description 107
3.23.2.2 Worker Activities 107
3.23.2.3 Inhalation Exposure Estimates 108
3.23.2.4 Dermal Exposure Results 109
3.23.3 Use of Formulations containing Formaldehyde in Fuels 109
3.23.3.1 Process Description 109
3.23.3.2 Worker Activities 109
3.23.3.3 Inhalation Exposure Estimates 109
3.23.3.4 Dermal Exposure Estimates Ill
3.24 Commercial Use - Chemical Substances in Agriculture Use Products -Lawn and Garden
Products Ill
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3,24,1 Use of Fertilizers Containing Formaldehyde in Outdoors Including Lawns Ill
3.24.1.1 Process Description Ill
3.24.1.2 Worker Activities Ill
3.24.1.3 Inhalation Exposure Estimates 112
3.24.1.4 Dermal Exposure Estimates 113
3.25 Commercial Use - Chemical Substances in Outdoor Use Products - Explosive Materials 113
3,25.1 Use of Explosive Materials 113
3.25.1.1 Process Description 113
3.25.1.2 Worker Activities 113
3.25.1.3 Inhalation Exposure Estimates 114
3.25.1.4 Dermal Exposure Estimates 114
3.26 Commercial Use - Chemical Substances in Packaging, Paper, Plastic, Hobby Products -
Paper Products; Plastic and Rubber Products; Toys, Playground, and Sporting Equipment.... 115
3.26.1 Use of Packaging, Paper, Plastics, and Hobby Products 115
3.26.1.1 Process Description 115
3.26.1.2 Worker Activities 115
3.26.1.3 Inhalation Exposure Estimates 115
3.26.1.4 Dermal Exposure Estimates 116
3.27 Commercial Use - Chemical Substances in Packaging, Paper, Plastic, and Hobby Products -
Arts, Crafts, and Hobby Materials 117
3,27.1 Use of Craft Materials 117
3.27.1.1 Process Description 117
3.27.1.2 Worker Activities 117
3.27.1.3 Inhalation Exposure Estimates 117
3.27.1.4 Dermal Exposure Estimates 117
3.28 Commercial Use - Chemical Substances in Packaging, Paper, Plastic, Hobby Products - Ink,
Toner, and Colorant Products; Photographic Supplies 118
3.28.1 Use of Printing Ink, Toner, and Colorant Products Containing Formaldehyde 118
3.28.1.1 Process Description 118
3.28.1.2 Worker Activities 119
3.28.1.3 Inhalation Exposure Estimates 120
3.28.1.4 Dermal Exposure Estimates 121
3.28.2 Photo Processing Using Formulations Containing Formaldehyde 121
3.28.2.1 Process Description 121
3.28.2.2 Worker Activities 122
3.28.2.3 Inhalation Exposure Estimates 122
3.28.2.4 Dermal Exposure Estimates 123
3.29 Commercial Use - Chemical Substances in Products Not Described by Other Codes -
Laboratory Chemicals 123
3.29.1 General Laboratory Use 123
3.29.1.1 Process Description 123
3.29.1.2 Worker Activities 124
3.29.1.3 Inhalation Exposure Estimates 125
3.29.1.4 Dermal Exposure Estimates 126
3.30 Disposal 126
3.30.1 Worker Handling of Wastes 126
3.30.1.1 Process Description 126
3.30.1.2 Worker Activities 127
3.30.1.3 Inhalation Exposure Estimates 128
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3.30.1.4 Dermal Exposure Estimates 129
4 WEIGHT OF SCIENTIFIC EVIDENCE: OCCUPATIONAL EXPOSURE
ESTIMATES 130
4.1 Strengths, Limitations, Assumptions, and Key Sources of Uncertainty for the Inhalation
Exposure Assessment 130
4.1.1 Manufacturing of Formaldehyde 132
4.1.2 Import and/or Repackaging of Formaldehyde 132
4.1.3 Processing as a Reactant 133
4.1.4 Textile Finishing 134
4.1.5 Use of Coatings, Paints, Adhesives, or Sealants 135
4.1.6 Rubber Product Manufacturing 136
4.1.7 Composite Wood Product Manufacturing 137
4.1.8 Other Composite Material Manufacturing 137
4.1.9 Paper Manufacturing 138
4.1.10 Plastic Product Manufacturing 139
4.1.11 Processing of Formaldehyde into Formulations, Mixtures, or Reaction Products 140
4.1.12 Recycling 141
4.1.13 Distribution of Commerce 141
4.1.14 Furniture Manufacturing 142
4.1.15 Processing Aid 143
4.1.16 Use of Formaldehyde for Oilfield Well Production 143
4.1.17 Industrial Use of Lubricants 144
4.1.18 Foundries 144
4.1.19 Installation and Demolition of Formaldehyde-Based Furnishings and
Building/Construction Materials in Residential, Public, and Commercial Buildings, and
Other Structures 145
4.1.20 Use of Formulations containing Formaldehyde for Water Treatment 146
4.1.21 Use of Formulations Containing Formaldehyde in Laundry and Dishwashing Products ... 147
4.1.22 Use of Electronic and Metal Products 147
4.1.23 Use of Formulations Containing Formaldehyde in Automotive Care Products 148
4.1.24 Use of Automotive Lubricants 148
4.1.25 Use of Formulations Containing Formaldehyde in Fuel 149
4.1.26 Use of Fertilizer Containing Formaldehyde in Outdoor Use Products 150
4.1.27 Use of Explosives 150
4.1.28 Use of Packaging, Paper, Plastics, and Hobby Products 151
4.1.29 Use of Craft Materials 151
4.1.30 Use of Printing Ink, Toner, and Colorant Products Containing Formaldehyde 152
4.1.31 Photo Processing Using Formulations Containing Formaldehyde 152
4.1.32 General Laboratory Use 152
4.1.33 Worker Handling of Waste 153
4.2 Strengths, Limitations, Assumptions, and Key Sources of Uncertainty for the Dermal
Exposure Assessment 154
REFERENCES 156
APPENDICES 176
Appendix A KEY ABBREVIATIONS AND ACRONYMS 176
Appendix B LIST OF SUPPLEMENTAL FILES 178
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Appendix C MODEL APPROACHES AND PARAMETER SELECTION 179
C.l EPA/OPPT Standard Models 179
C.2 Developing Models that Use Monte Carlo Methods 182
C.2.1 Background on Monte Carlo Methods 182
C.2.2 Implementation of Monte Carlo Methods 182
C.2.3 Building the Model 183
C.2.3.1 Build the Deterministic Model 183
C.2.3.2 Define Probability Distributions for Input Parameters 183
C.2.3.3 Select Model Outputs for Aggregation of Simulation Results 187
C.2.3.4 Select Simulation Settings and Run Model 187
C.2.3.5 Aggregate the Simulation Results and Produce Output Statistics 187
C.3 Use of Formulations Containing Formaldehyde in Automotive Care Products Model
Approach and Parameters 187
C.3.1 Model Equations 188
C.3.2 Model Input Parameters 188
C.3.3 Throughput Parameters 191
C.3.4 Concentration of Formaldehyde 191
C.3.5 Exposure Duration 191
C.3.6 Lifetime Years 191
C.3.7 Operating Days 191
C.3.8 Saturation Factor 191
C.3.9 Diameters of Opening 191
C.3.10 Worker Years 192
C.3.11 Container Size 193
C.3.12 Container Fill Rates 193
C.3.13 Ventilation Rate 194
C.3.14 Mixing Factor 194
C.3.15 Exposure Days Fraction 194
C.4 Industrial Use of Lubricants 194
C.4.1 Model Equations 195
C.4.2 Model Input Parameters 195
C.4.3 Annual Facility Throughput 198
C.4.4 Concentration of Formaldehyde 198
C.4.5 Exposure Duration 198
C.4.6 Lifetime Years 198
C.4.7 Operating Days 198
C.4.8 AirSpeed 198
C.4.9 Saturation Factor 199
C.4.10 Diameters of Opening 199
C.4.11 Worker Years 199
C.4.12 Container Size 201
C.4.13 Container Fill Rates 201
C.4.14 Ventilation Rate 201
C.4.15 Mixing Factor 201
C.5 Use of Formulations Containing Formaldehyde for Water Treatment Model Approach and
Parameters 202
C,6 Use of Fertilizers Containing Formaldehyde in Outdoors including Lawns 202
C.6.1 Model Equations 202
C.6.2 Model Input Parameters 202
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C.6.3 Fertilizer Use Rate 206
C.6.4 Concentration of Formaldehyde 206
C.6.5 Exposure Duration 206
C.6.6 Lifetime Years 206
C.6.7 AirSpeed 206
C.6.8 Saturation Factor 207
C.6.9 Diameters of Opening 207
C.6.10 Worker Years 207
C.6.11 Container Size 209
C.6.12 Container Fill Rates 209
C.6.13 Ventilation Rate 209
C.6.14 Mixing Factor 209
C.6.15 Hours of Exposure for Equipment Cleaning 210
C.6.16 Fertilizer Density 210
C.6.17 Generic Model for Central Tendency and High-End Inhalation Exposure to Total and
Respirable PNOR 210
C,7 Use of Formaldehyde for Oilfield Well Production 210
C.7.1 Model Equations 211
C.7.2 Model Input Parameters 211
C.7.3 FracFocus Parameters 214
C.7.4 Container Volume 214
C.7.5 Container Fill Rate 215
C.7.6 Diameters of Openings 215
C.7.7 AirSpeed 215
C.7.8 Saturation Factor 215
C.7.9 Ventilation Rate 215
C.7.10 Mixing Factor 215
C.7.11 Worker Years 215
C.7.12 Exposure Activity Hours 217
C.8 Tank Truck and Railcar Loading and Unloading Release and Inhalation Exposure Model
Methodology 218
C.8.1 Displacement of Saturated Air Inside Tank Truck and Railcars 218
C.8.2 Emissions of Saturated Air inside Tank Truck and Railcars 219
C.8.3 Emissions from Leaks 221
C.8.4 Exposure Estimates 221
C.9 Generic Model for Central Tendency and High-End Inhalation Exposure to Total and
Respirable Particulates Not Otherwise Regulated (PNOR) 223
C.10 Dermal Exposure Model Methodology 224
C.10.1 Model Input Parameters 224
Appendix D CROSSWALK OF NAICS CODES TO OES FOR OSHA CEHD DATA
ANALYSIS 225
Appendix E ANAYLSIS OF FULL SHIFT CALCULATIONS OF OSHA CEHD DATA 257
Appendix F CONSIDERATION OF ENGINEERING CONTROLS AND PERSONAL
PROTECTIVE EQUIPMENT 263
F.l Respiratory Protection 263
F.2 Glove Protection 266
Appendix G FACILITY ESTIMATES AND NUMBER OF WORKERS 268
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G.l Manufacturing of Formaldehyde 268
G.2 Import and/or Repackaging of Formaldehyde 269
G,3 Processing as a Reactant 270
G.4 Composite Wood Product Manufacturing 272
G.5 Other Composite Material Manufacturing (e.g., Roofing) 273
G.6 Textile Finishing 275
G,7 Leather Tanning 276
G.8 Rubber Product Manufacturing 277
G.9 Paper Manufacturing 277
G.10 Plastic Product Manufacturing 278
G.l 1 Processing of Formaldehyde into Formulations, Mixtures, or Reaction Products 279
G.12 Recycling 282
G.l3 Storage and Retail Stores 282
G.l4 Furniture Manufacturing 284
G.l5 Processing Aid 286
G.16 Use of Formaldehyde for Oilfield Well Production 288
G.l 7 Use of Coatings, Paints, Adhesives, or Sealants (non-spray applications) 289
G.l 8 Industrial Use of Lubricants 290
G.l9 Foundries 291
G.20 Installation and Demolition of Formaldehyde-Based Furnishings and Building/Construction
Materials in Residential, Public, and Commercial Buildings, and Other Structures 292
G.21 Use of Formulations Containing Formaldehyde for Water Treatment 294
G.22 Use of Formulations Containing Formaldehyde in Laundry and Dishwashing Products 294
G.23 Use of Formulations Containing Formaldehyde for Spray Applications (e.g., Spray or Roll). 295
G.24 Use of Electronic and Metal Products 298
G.25 Use of Formulations Containing Formaldehyde in Fuels 299
G.26 Use of Automotive Lubricants 300
G.27 Use of Formulations Containing Formaldehyde in Automotive Care Products 301
G.28 Use of Fertilizers Containing Formaldehyde in Outdoors Including Lawns 302
G.29 Use of Explosive Materials 302
G.30 Use of Packaging, Paper, Plastics, and Hobby Products 303
G.31 Use of Craft Materials 304
G.32 Use of Printing Ink, Toner, and Colorant Products Containing Formaldehyde 304
G.33 Photo Processing Using Formulations Containing Formaldehyde 305
G.34 General Laboratory Use 306
G.35 Worker Handling of Wastes 307
Appendix H EXAMPLE OF ESTIMATING NUMBER OF WORKERS AND
OCCUPATIONAL NON-USERS 309
LIST OF TABLES
Table 1-1. Crosswalk of COU Subcategories to Occupational Exposure Scenarios Assessed in the
Risk Evaluation 22
Table 3-1. Physical Forms of Formaldehyde Reported in 2020 CDR 38
Table 3-2. Formaldehyde Concentrations Reported in 2020 CDR 38
Table 3-3. Manufacturing Inhalation Exposure Data Evaluation 39
Table 3-4. Summary of Inhalation Exposure Monitoring Data for Manufacturing OES 40
Table 3-5. Repackaging Inhalation Exposure Data Evaluation 43
Table 3-6. Summary of Inhalation Exposure Monitoring Data for Repackaging 43
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Table 3-7. Processing as a Reactant Inhalation Exposure Data Evaluation 48
Table 3-8. Summary of Inhalation Exposure Monitoring Data for Processing as a Reactant 50
Table 3-9. Textile Finishing Inhalation Exposure Data Evaluation 53
Table 3-10. Summary of Inhalation Exposure Monitoring Data for Textile Finishing 54
Table 3-11. Use of Formulations Containing Formaldehyde for Spray or Unknown Applications (e.g.,
Spray or Roll) Inhalation Exposure Data Evaluation 59
Table 3-12. Summary of Inhalation Exposure Monitoring Data for Use of Formulations Containing
Formaldehyde for Spray Applications (e.g., Spray or Roll) 60
Table 3-13. Use of Coatings, Paints, Adhesives, or Sealants (Non-spray Applications) Inhalation
Exposure Data 61
Table 3-14. Summary of Inhalation Exposure Monitoring Data for Use of Coatings, Paints,
Adhesives, or Sealants (Non-spray Applications) 61
Table 3-15. Rubber Product Manufacturing Inhalation Exposure Data Evaluation 63
Table 3-16. Summary of Inhalation Exposure Monitoring Data for Rubber Product Manufacturing 64
Table 3-17. Composite Wood Product Manufacturing Inhalation Exposure Data Evaluation 66
Table 3-18. Summary of Inhalation Exposure Monitoring Data for Composite Wood Product
Manufacturing 67
Table 3-19. Other Composite Material Manufacturing (e.g., Roofing) Inhalation Exposure Data
Evaluation 69
Table 3-20. Summary of Inhalation Exposure Monitoring Data for Other Composite Material
Manufacturing (e.g., Roofing) 70
Table 3-21. Paper Manufacturing Inhalation Exposure Data Evaluation 71
Table 3-22. Summary of Inhalation Exposure Monitoring Data for Paper Manufacturing 72
Table 3-23. Plastic Product Manufacturing Inhalation Exposure Data Evaluation 74
Table 3-24. Summary of Inhalation Exposure Monitoring Data for Plastic Product Manufacturing 75
Table 3-25. Processing of Formaldehyde into Formulations, Mixtures, or Reaction Products
Inhalation Exposure Data Evaluation 78
Table 3-26. Summary of Inhalation Exposure Monitoring Data for Processing of Formaldehyde into
Formulations, Mixtures, or Reaction Products 79
Table 3-27. Recycling Data Evaluation 80
Table 3-28. Summary of Inhalation Monitoring Data for Recycling 81
Table 3-29. Storage and Retail Stores Inhalation Exposure Data Evaluation 82
Table 3-30. Summary of Inhalation Exposure Monitoring Data for Storage and Retail 83
Table 3-31. Furniture Manufacturing Inhalation Exposure Data Evaluation 84
Table 3-32. Summary of Inhalation Exposure Monitoring Data for Furniture Manufacturing 85
Table 3-33. Processing Aid Inhalation Exposure Data Evaluation 86
Table 3-34. Summary of Inhalation Exposure Monitoring Data for Processing Aid 87
Table 3-35. Summary of Inhalation Exposure Modeling Data for the Use of Formaldehyde for
Oilfield Well Production - 60% Mass Concentration Cap Approach 90
Table 3-36. Summary of Inhalation Exposure Modeling Data for the Use of Formaldehyde for
Oilfield Well Production - 37% Mass Concentration Adjustment Approach 91
Table 3-37. Summary of Inhalation Exposure Modeling Data for the Industrial Use of Lubricants 93
Table 3-38. Foundries Inhalation Exposure Data Evaluation 94
Table 3-39. Summary of Inhalation Exposure Monitoring Data for Foundries 95
Table 3-40. Installation and Demolition of Formaldehyde-Based Furnishings and
Building/Construction Materials in Residential, Public and Commercial Buildings, and
Other Structures Inhalation Exposure Data Evaluation 97
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Table 3-41. Summary of Inhalation Exposure Monitoring Data for Installation and Demolition of
Formaldehyde-Based Furnishings and Building/Construction Materials in Residential,
Public and Commercial Buildings, and Other Structures 98
Table 3-42. Summary of Inhalation Exposure Modeling Data for the Use of Formulations Containing
Formaldehyde for Water Treatment 100
Table 3-43. Use of Formulations Containing Formaldehyde in Laundry and Dishwashing Products... 101
Table 3-44. Summary of Inhalation Exposure Monitoring Data for Use of Formulations Containing
Formaldehyde in Laundry and Dishwashing Products 102
Table 3-45. Use of Electronic and Metal Products Inhalation Exposure Data Evaluation 104
Table 3-46. Summary of Inhalation Exposure Monitoring Data for Use of Electronic and Metal
Products 104
Table 3-47. Summary of Inhalation Exposure Modeling Data for the Use of Formulations Containing
Formaldehyde in Automotive Care Products 106
Table 3-48. Use of Automotive Lubricants Inhalation Exposure Data Evaluation 108
Table 3-49. Summary of Inhalation Exposure Monitoring Data for the Use of Automotive Lubricantsl08
Table 3-50. Use of Formulations Containing Formaldehyde in Fuels Inhalation Exposure Data
Evaluation 109
Table 3-51. Summary of Inhalation Exposure Monitoring Data for the Use of Formulations
containing Formaldehyde in Fuels 110
Table 3-52. Summary of Inhalation Exposure Modeling Data for the Use of Fertilizers Containing
Formaldehyde in Outdoors Including Lawns 112
Table 3-53. Use of Explosive Materials Inhalation Exposure Data Evaluation 114
Table 3-54. Summary of Inhalation Exposure Monitoring Data for the Use of Explosive Materials.... 114
Table 3-55. Use of Packaging, Paper, and Hobby Products Inhalation Exposure Data Evaluation 115
Table 3-56. Summary of Inhalation Exposure Monitoring Data for the Use of Packaging, Paper, and
Hobby Products 116
Table 3-57. Use of Printing Ink, Toner, and Colorant Products Inhalation Exposure Data Evaluation. 120
Table 3-58. Summary of Inhalation Exposure Monitoring Data for the Use of Printing Ink, Toner, and
Colorant Products Containing Formaldehyde 121
Table 3-59. Photo Processing Using Formulations Containing Formaldehyde Inhalation Exposure
Data Evaluation 122
Table 3-60. Photo Processing Using Formulations Containing Formaldehyde 123
Table 3-61. General Laboratory Use Inhalation Exposure Data Evaluation 125
Table 3-62. Summary of Inhalation Exposure Monitoring Data for General Laboratory Use 126
Table 3-63. Worker Handling of Wastes Inhalation Exposure Data Evaluation 128
Table 3-64. Summary of Inhalation Exposure Monitoring Data for Worker Handling of Wastes 129
Table 4-1. Comparison of Dermal Exposure Values 154
LIST OF FIGURES
Figure 1-1. Condition of Use to Occupational Exposure Mapping 20
Figure 3-1. Typical Release and Exposure Points During Chemical Repackaging (U.S. EPA, 2022a)... 42
Figure 3-2. Process Flow Diagram for the Manufacturing of Urea (U.S. EPA, 1995b) 45
Figure 3-3. Typical Release and Exposure Points for the Use of Adhesives Containing Formaldehyde
(OECD, 2015b) 55
Figure 3-4. General Radiation Curable Coating Process (OECD, 201 lb) 57
Figure 3-5. Automotive Refinishing Spray Coating Processes (OECD, 201 la) 58
Figure 3-6. Preliminary Process Flow Diagram with Releases and Exposures for Oil Well Production
(OECD, 2012) 89
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Figure 3-7. Typical Release and Exposure Points During the Use of Formaldehyde in Printing Inks
(U.S. EPA, 2010) 119
Figure 3-8. Typical Exposure Points During the Use of Formaldehyde in Laboratory Chemicals (U.S.
EPA, 2023 d) 124
Figure 3-9. Typical Hazard Waste Disposal Process (U.S. EPA, 2017a) 127
LIST OF APPENDIX TABLES
TableApx C-l. Models and Variables Applied for Exposure Points in the Automotive Care OES 188
TableApx C-2. Summary of Parameter Values and Distributions Used in the Automotive Care
Products Models 189
TableApx C-3. Overview of Average Worker Tenure from U.S. Census SIPP (Age Group 50+) 193
Table_Apx C-4. Median Years of Tenure with Current Employer by Age Group 193
Table Apx C-5. Models and Variables Applied for Exposure Points in the Industrial Use of
Lubricants OES 195
Table Apx C-6. Summary of Parameter Values and Distributions Used in the Use of Lubricants
containing Formaldehyde 196
Table_Apx C-l. Overview of Average Worker Tenure from U.S. Census SIPP (Age Group 50+) 200
Table_Apx C-8. Median Years of Tenure with Current Employer by Age Group 201
Table Apx C-9. Models and Variables Applied for Exposure Points in the Use of Fertilizer OES 203
Table Apx C-10. Summary of Parameter Values and Distributions Used in the Use of Fertilizer
Models 204
TableApx C-l 1. Overview of Average Worker Tenure from U.S. Census SIPP (Age Group 50+) .... 208
Table_Apx C-12. Median Years of Tenure with Current Employer by Age Group 209
Table Apx C-13. Summary of DIDP Exposure Estimates for OESs Using the Generic Model for
Exposure to PNOR 210
Table Apx C-14. Models and Variables Applied for Exposure Points in the Use of Formaldehyde in
Oilfield Well Production 211
TableApx C-15. Summary of Parameter Values and Distributions Used in the Use of Formaldehyde
for Oilfield Well Production Models 212
TableApx C-16. Overview of Average Worker Tenure from U.S. Census SIPP (Age Group 50+) .... 216
Table_Apx C-17. Median Years of Tenure with Current Employer by Age Group 217
TableApx C-l 8. Example Dimension and Volume of Loading Arm/Transfer System 220
Table Apx C-19. Default Values for Calculating Emission Rate of Formaldehyde from
Transfer/Loading Arm 220
Table Apx C-20. Parameters for Calculating Emission Rate of Formaldehyde from Equipment
Leaks 221
Table Apx C-21. Parameters for Calculating Exposure Concentration Using the EPA/OPPT Mass
Balance Model 222
Table Apx C-22. Calculated Emission Rates and Resulting Exposures from the Tank Truck and
Railcar Loading and Unloading Release and Inhalation Exposure Model for
Formaldehyde 223
Table_Apx C-23. Total PNOR Default Concentrations 224
Table_Apx D-l. Mapping of NAICS Codes to OES 225
Table Apx E-l. Analysis of OSHA CEHD Formaldehyde Data from 1992 to 2021 (All Samples) 258
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TableApx E-2. Analysis of OSHA CEHD Formaldehyde Data from 1992 to 2021 (Total Samples
Times >330 Minutes) a 260
Table Apx E-3. Sampling Concentration Results for Processing of Formaldehyde into Formulations,
Mixtures, or Reaction Products 262
Table Apx E-4. Sampling Concentration Results for Paper Manufacturing 262
Table Apx F-l. Assigned Protection Factors for Respirators in OSHA Standard 29 CFR 1910.134 ... 264
Table Apx F-2. Number and Percent of Establishments and Employees Using Respirators within 12
Months Prior to Survey 266
Table Apx F-3. Glove Protection Factors for Different Dermal Protection Strategies from ECETOC
TRA V3 267
Table_Apx G-l. Number of Workers for Manufacturing 269
Table Apx G-2. Number of Workers for Import and/or Repackaging of Formaldehyde 270
Table_Apx G-3. Number of Workers for Processing as a Reactant 271
Table Apx G-4. Number of Workers for Composite Wood Product Manufacturing 273
Table_Apx G-5. Number of Workers for Other Composite Material Manufacturing 274
Table_Apx G-6. Number of Workers for Textile Finishing 275
Table_Apx G-l. Number of Workers for Leather Tanning 276
Table_Apx G-8. Number of Workers for Rubber Product Manufacturing 277
Table_Apx G-9. Number of Workers for Paper Manufacturing 278
Table_Apx G-10. Number of Workers for Plastic Product Manufacturing 279
TableApx G-ll. Number of Workers for Processing of Formaldehyde into Formulations, Mixture,
or Reaction Products 280
Table_Apx G-12. Number of Workers for Recycling 282
Table_Apx G-13. Number of Workers in Storage and Retail Stores 283
Table_Apx G-14. Number of Workers for Furniture Manufacturing 285
Table_Apx G-15. Number of Workers for Processing Aid 286
Table Apx G-16. Use of Formaldehyde for Oilfield Well Production 289
Table_Apx G-17. Number of Workers for Use of Coatings, Paints, Adhesives, or Sealants 290
Table_Apx G-18. Number of Workers for Industrial Use of Lubricants 291
Table_Apx G-19. Number of Workers for Foundries 291
Table Apx G-20. Number of Workers for Installation and Demolition of Formaldehyde-Based
Furnishings and Building/Construction Materials in Residential, Public, Commercial
Buildings, and Other Structures 293
Table Apx G-21. Number of Workers for Use of Formulations Containing Formaldehyde for Water
Treatment 294
Table Apx G-22. Number of Workers for Use of Formulations containing Formaldehyde in Laundry
and Dishwashing Products 295
TableApx G-23. Number of Workers for Use of Formulations Containing Formaldehyde for Spray
Applications (e.g., Spray or Roll) 295
Table_Apx G-24. Number of Workers for Use of Electronics and Metal Products 299
TableApx G-25. Number of Workers for Use of Formulations Containing Formaldehyde in Fuels... 300
Table_Apx G-26. Number of Workers for Use of Automotive Lubricants 301
Table Apx G-27. Number of Workers for Use of Formulations Containing Formaldehyde in
Automotive Care Products 302
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TableApx G-28. Number of Workers for Use of Fertilizers containing Formaldehyde in Outdoors
including Lawns 302
Table_Apx G-29. Number of Workers for Use of Explosive Materials 303
TableApx G-30. Number of Workers for Use of Packaging, Paper, Plastics, and Hobby Products .... 304
Table_Apx G-31. Number of Workers for Use of Craft Materials 304
Table Apx G-32. Number of Workers for Use of Printing Ink, Toner, and Colorant Products 305
TableApx G-33. Number of Workers for Photo Processing Using Formulations Containing
Formaldehyde 306
Table_Apx G-34. Number of Workers for General Laboratory Use 307
Table_Apx G-35. Number of Workers for Worker Handling of Waste 308
TableApx H-l. SOCs with Worker and ONU Designations for All Conditions of Use Except Dry
Cleaning 310
Table Apx H-2. SOCs with Worker and ONU Designations for Dry Cleaning Facilities 311
TableApx H-3. Estimated Number of Potentially Exposed Workers and ONUs under NAICS
812320 312
LIST OF APPENDIX FIGURES
FigureApx C-l. Flowchart of a Monte Carlo Method Implemented in a Microsoft Excel-Based
Model Using a Monte Carlo Add-In Tool 183
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EXECUTIVE SUMMARY
Key Points: Omipsilionsil Kxposnre Assessment lor lonnnldchydc
• I-PA estimated occupational exposures lo formaldehyde through aii' (inhalalion) ancl skin
contact (dermal) routes The Agency estimated both hiuh-end ancl central tendency exposure
estimates for occii|")ational exposure scenarios (OLSs) associated with each Toxic Substances
Control Act (TSCA) condition of use (COl )
• Inhalation exposure for most OLSs were estimated based 011 monitoring data. lor OLSs that
lacked reasonably a\ ai I able monitorinu data. LPA generally applied Monte Carlo statistical
modeling approaches to estimate exposures
• I-1\\ estimated lull-shift exposure concentrations {i.e.. X-hour time-weighted a\eraues.
TWA. or 12-hour TWA) and short-term exposure concentrations {e.g.. 33<) minutes).
• The fill I-shift inhalation exposure estimates for the Ol-Ss ranged from ^ .>4 ¦ in " to n 44
ppm for central tendency exposures and 0 <><>7 to 14 ppm for hiuh-end exposures
• The short-term inhalation exposure estimates for the Ol-Ss ranued from 0 <><>2 to I (->2 ppm
for central tendency exposures and mw to 171 ppm for hiuh-end exposures
• All of the dermal exposures were modeled using LPA OPPT Dermal Contact with Liquid
Models
• The dermal exposure estimates ranued from 0 5(-> to 1.14') uu m' for central tendency
exposures and <> X4 to liwn uu m' for hiuh-end exposures
EPA estimated inhalation exposures to workers and occupational non-users (ONUs) and dermal
exposures for workers for the TSCA COUs. These COUs cover formaldehyde as it is manufactured,
processed, used, distributed in commerce, or disposed of. For exposure estimates, EPA reviewed
monitoring data from peer-reviewed literature, gray literature, or industry submissions, as well as
modeling approaches to estimate both a central tendency and a high-end estimate for each route.
Workers and ONUs are exposed by the inhalation route as formaldehyde is a volatile chemical and is
known to off-gas from formaldehyde-based products. Workers are dermally exposed to formaldehyde
from skin contact with formulations containing formaldehyde.
EPA did not quantitatively evaluate occupational exposures to formaldehyde through the oral route.
Workers and ONUs might inadvertently ingest inhaled particles that deposit in the upper respiratory
tract. In addition, workers may transfer chemicals from their hands to their mouths. The frequency and
significance of these exposure routes are dependent on several factors that are difficult to predict.
Formaldehyde is highly volatile and generally not expected to adhere to dust or other particles, which
could then be ingested. For certain COUs, wood or textile dust may act as a carrier for formaldehyde
leading to inhalation via particulate that could be subsequently ingested. However, there is uncertainty in
the amount ingested due to formaldehyde's volatility. For this risk assessment, these exposures were
evaluated as an inhalation exposure.
EPA primarily integrated discrete monitoring sampling data for the central tendency and high-end
inhalation estimates. The inhalation exposure estimates for full-shift (i.e., 8- or 12-hour TWAs) ranged
from 9.34x 10-6 to 0.44 ppm for the central tendency results, and 0.007 to 14 ppm for the high-end
results. The highest inhalation exposure estimates were for use of formulations containing formaldehyde
in automotive care products. For shorter term (<330 minutes) exposures, the inhalation estimates ranged
Page 16 of 313
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from 0.002 to 1.62 ppm for the central tendency results and 0.09 to 171 ppm for the high-end results.
These estimates are values unadjusted by use of personal protective equipment.
Dermal exposure estimates were driven by the expected dermal contact scenario (e.g., routine or
immersion) and the formaldehyde concentration within the formulation. Dermal exposure values ranged
from 0.56 to 1,140 |ig/m3 for central tendency estimates and 0.84 to 3,090 |ig/m3 for high-end estimates.
The highest dermal exposure estimates were for use of formulations containing formaldehyde for
manual spray applications and use of formulations containing formaldehyde in automotive care
products.
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1 INTRODUCTION
EPA is evaluating risks from formaldehyde under both FIFRA and the Toxic Substances Control Act
(TSCA), as amended by the Frank R. Lautenberg Chemical Safety for the 21st Century Act. This
occupational exposure assessment specifically focuses on worker exposures to formaldehyde resulting
from conditions of use (COUs) under TSCA as part of the Risk Evaluation for formaldehyde.
Formaldehyde is used in several processing activities, including use as a reactant, incorporation into
articles, and incorporation into a formulation, mixture, or reaction product for various industrial,
commercial, and consumer applications. Formaldehyde is widely used in industrial, commercial, and
consumer applications such as textiles, foam bedding/seating, resins, glues, composite wood products,
paints, coatings, plastics, rubber, construction materials (including insulation and roofing), furniture,
toys, and various adhesives and sealants.
Formaldehyde is subject to federal and state regulations and reporting requirements. Formaldehyde is a
Toxics Release Inventory (TRI)-reportable substance. It is also on EPA's initial list of hazardous air
pollutant (HAPs) under the Clean Air Act (CAA), is a designated hazardous substance under the Clean
Water Act (CWA), and has a drinking water health advisory (non-enforceable guideline) under the Safe
Drinking Water Act (SDWA). Formaldehyde has an Occupational Safety and Health Administration
(OSHA) standard at 29 CFR 1910.1048. The permissible exposure limit (PEL) is 0.75 parts per million
(ppm) over an 8-hour (full shift) workday, time-weighted average (TWA), and a short-term exposure
limit (STEL) of 2 ppm. The OSHA standard also includes but is not limited to requirements for exposure
monitoring, dermal protection, recordkeeping, use of personal protective equipment (PPE) if other
exposure controls are not feasible, and hazard communication.
There are also recommended exposure limits established for formaldehyde by other governmental
agencies and independent groups. The American Conference of Governmental Industrial Hygienists
(ACGIH) set a Threshold Limit Value (TLV) at 0.1 ppm TWA and 0.3 ppm STEL in 2017. This
chemical also has a NIOSH Recommended Exposure Limit (REL) of 0.016 ppm TWA and 15-minute
Ceiling limit of 0.1 ppm (see NIOSH Pocket Guide to Chemical Hazards).
1.1 Changes between Draft and Revised Assessment
EPA has made the following key changes from the draft to the finalized occupational exposure
assessment of formaldehyde:
• In Section 3, EPA integrated recently submitted occupational monitoring data received during
the public comment period.
• EPA expanded the acute exposure analysis by including multiple short-term estimates
categorized by sample durations. In the draft risk evaluation, the Agency only extracted full-shift
estimates and 15-minute samples from the OSHA database; however, EPA considered
measurements from OSHA sampled outside of those time ranges. In the revised assessment, EPA
provides the central tendency and high-end estimates based on 15-minute samples, as well as
samples taken for more than 15-minutes but less than 330 minutes. Based on public comments,
the Agency also provides the estimates for samples taken between 15-minutes and 60-minutes.
• In Section 3.24.1, EPA revised the modeling for the use of fertilizer based on industry
information on expected exposure frequencies and durations.
• In Section 3.14.1, EPA revised the approach for Use of formaldehyde for oilfield well production
OES and used Monte-Carlo modeling to estimate occupational exposures.
• EPA also made corrections and revised assignment of OSHA data to occupational exposure
scenarios (OESs), as needed.
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1.2 Scope
EPA assessed occupational exposures for COUs as described below and summarized in Table 1-1. EPA
did not include in the scope of the risk evaluation activities described below that the Agency does not
consider to be COUs. TSCA section 3(2)(B) excludes from the definition of "chemical substance" "any
food, food additive, drug, cosmetic, or device (as such terms are defined in Section 201 of the Federal
Food, Drug, and Cosmetic Act [21 U.S.C. 321]) when manufactured, processed, or distributed in
commerce for use as a food, food additive, drug, cosmetic, or device" as well as "any pesticide (as
defined in the Federal Insecticide, Fungicide, and Rodenticide Act [7 U.S.C. 136 et seq.]) when
manufactured, processed, or distributed in commerce for use as a pesticide." EPA has determined that
the following uses of formaldehyde are non-TSCA uses that fall under the TSCA section 3(2)(B)
exclusions and therefore the following exposure scenarios are not assessed in this assessment:
• use in food packaging;
• use in manufacturing medical devices;
• use in sterilization of kidney dialysis machines;
• use in nail and hair care products;
• use in the manufacture of animal feeds (21 CFR 573.460);
• use as a drug in fish hatcheries (21 CFR 529.1004);
• use as a biocide in fumigation at poultry hatcheries, citric houses; and
• use as an embalming fluid or preservative for biological specimen.
Formaldehyde can be emitted from many types of combustion, ranging from naturally occurring
wildfires to household appliance and industrial combustion turbines. These sources can also include
tailpipe emissions (including cars, trucks, and boats); and emissions from fires (including accidental
fires, and agricultural burning). Exposures from at least some of the combustion activities that occur at
industrial sites may have been integrated into the other associated TSCA COUs. Workers such as
firefighters or staff at transportation terminals may have heightened occupational exposures from
formaldehyde due to these combustion sources. For the occupational exposure assessment in this risk
evaluation, given the number and variety of potential combustion sources, EPA did not evaluate
formaldehyde exposures from combustion sources independent of other TSCA COUs. EPA provides
summaries of select monitoring studies associated with combustion in Supplemental Formaldehyde
Occupational Monitoring Data Summary and the full list of studies identified in Risk Evaluation for
Formaldehyde (HCHO) - Systematic Review Supplemental File: Data Quality Evaluation and Data
Extraction Information for Environmental Release and Occupational Exposure (U.S. EPA. 2024b).
EPA identified OESs related to the in-scope COUs of formaldehyde. An OES is a set of facts,
assumptions, and inferences that describe how releases and exposures take place within an occupational
COU. For each OES, EPA has developed assessment approaches to provide estimates of central
tendency and high-end exposures that are representative of the OES. The central tendency and high-end
exposures represent the 50th and 95th percentile of exposure estimates, respectively. EPA may define
only a single OES for multiple COUs, while in other cases multiple OESs may be developed for a single
COU. The Agency will make this determination by considering variability in the use conditions and
whether the variability can be captured as a distribution of exposure or instead requires discrete
scenarios. Figure 1-1 depicts three ways that COUs may be mapped to OES.
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-o
o
cou
OES
COUs identified for the chemical during scoping are reviewed to
determine potential release and exposure scenarios (referred to as OES)
COU to OES mapping may come in many forms, as shown in this figure
One COU may map to one OES
-------
• Occupational Inhalation Exposure Results: Provide central tendency and high-end estimates
of inhalation exposure to workers and ONUs; see Section 2.5 for a discussion of EPA's statistical
analysis approach for assessing inhalation exposure.
• Occupational Dermal Exposure Results: Provide central tendency and high-end estimates of
dermal exposure to workers; see Section 2.6 for a discussion of EPA's approach for assessing
dermal exposure.
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Table 1-1. Crosswalk of CPU Subcategories to Occupational Exposure Scenarios Assessed in the Risk Evaluation
Condition of Use (COU)
Occupational Exposure Scenario
(OES) Mapped to COU
Life Cycle
Stage
Category
Subcategory
Manufacturing
Domestic
Manufacturing
Domestic manufacturing
Manufacturing of Formaldehyde
Importing0
Importing
Import and/or Repackaging of
Formal deli vde
Processing
Reactant
Adhesives and sealant chemicals in: Plastic and resin manufacturing;
Wood product manufacturing; Paint and coating manufacturing; basic
organic chemical manufacturing
Processing as a Reactant
Processing
Reactant
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; Agriculture, forestry, fishing, and hunting
Processing
Reactant
Functional fluid in: Oil and gas drilling, extraction, and support activities
Processing
Reactant
Processing aids, specific to petroleum production in all other basic
chemical manufacturing
Processing
Reactant
Bleaching agent in wood product manufacturing
Processing
Reactant
Agricultural chemicals in agriculture, forestry, fishing, and hunting
Processing
Incorporation into an
article
Finishing agents in textiles, apparel, and leather manufacturing
Textile Finishing
Processing
Incorporation into an
article
Paint additives and coating additives not described by other categories in
transportation equipment manufacturing (including aerospace)
Use of Coatings. Paints. Adhesives. or
Sealants
Processing
Incorporation into an
article
Additive in rubber product manufacturing
Rubber Product Manufacturing
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Condition of Use (COU)
Occupational Exposure Scenario
(OES) Mapped to COU
Life Cycle
Stage
Category
Subcategory
Processing
Incorporation into an
article
Adhesives and sealant chemicals in wood product manufacturing; plastic
material and resin manufacturing (including structural and fireworthy
aerospace interiors); construction (including roofing materials); paper
manufacturing
Composite Wood Product
Manufacturing
Other Composite Material
Manufacturing
Paoer Manufacturing
Plastic Product Manufacturing
Processing
Incorporation into a
formulation, mixture,
or reaction product
Petrochemical manufacturing, petroleum, lubricating oil and grease
manufacturing; fuel and fuel additives; lubricant and lubricant additives;
basic organic chemical manufacturing; petroleum and coal products
manufacturing
Processing of Formaldehyde into
Formulations. Mixtures, or Reaction
Products
Incorporation into a
formulation, mixture,
or reaction product
Asphalt, paving, roofing, and coating materials manufacturing
Incorporation into a
formulation, mixture,
or reaction product
Solvents (which become part of a product formulation or mixture) in
paint and coating manufacturing
Incorporation into a
formulation, mixture,
or reaction product
Processing aids, specific to petroleum production in: oil and gas drilling,
extraction, and support activities; chemical product and preparation
manufacturing; and basic inorganic chemical manufacturing
Incorporation into a
formulation, mixture,
or reaction product
Paint additives and coating additives not described by other categories
in: Paint and coating manufacturing; Plastic material and resin
manufacturing
Incorporation into a
formulation, mixture,
or reaction product
Intermediate in: all other basic chemical manufacturing; all other
chemical product and preparation manufacturing; plastic material and
resin manufacturing; oil and gas drilling, extraction, and support
activities; wholesale and retail trade
Incorporation into a
formulation, mixture,
or reaction product
Solid separation agents in miscellaneous manufacturing
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Condition of Use (COU)
Occupational Exposure Scenario
(OES) Mapped to COU
Life Cycle
Stage
Category
Subcategory
Processing
Incorporation into a
formulation, mixture,
or reaction product
Agricultural chemicals (nonpesticidal) in: Agriculture, forestry, fishing,
and hunting; pesticide, fertilizer, and other agricultural chemical
manufacturing
Incorporation into a
formulation, mixture,
or reaction product
Surface active agents in plastic material and resin manufacturing
Incorporation into a
formulation, mixture,
or reaction product
Ion exchange agents in adhesive manufacturing and paint and coating
manufacturing
Incorporation into a
formulation, mixture,
or reaction product
Lubricant and lubricant additive in adhesive manufacturing
Incorporation into a
formulation, mixture,
or reaction product
Plating agents and surface treating agents in all other chemical product
and preparation manufacturing
Incorporation into a
formulation, mixture,
or reaction product
Soap, cleaning compound, and toilet preparation manufacturing
Incorporation into a
formulation, mixture,
or reaction product
Laboratory chemicals
Incorporation into a
formulation, mixture,
or reaction product
Adhesive and sealant chemical in adhesive manufacturing
Incorporation into a
formulation, mixture,
or reaction product
Bleaching agents in textile, apparel, and leather manufacturing
Repackaging
Sales to distributors for laboratory chemicals
Import and/or Repackaging of
Formaldehyde
Recycling
Recycling
Recycling
Distribution
Distribution
Distribution in Commerce
Storage and Retail Stores
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Condition of Use (COU)
Occupational Exposure Scenario
(OES) Mapped to COU
Life Cycle
Stage
Category
Subcategory
Industrial Use
Non-incorporative
activities
Process aid in: Oil and gas drilling, extraction, and support activities;
process aid specific to petroleum production, hydraulic fracturing
Use of Formaldehyde for Oilfield
Well Production
Industrial Use
Non-incorporative
activities
Used in: construction
Furniture Manufacturing
Industrial Use
Non-incorporative
activities
Oxidizing/reducing agent; processing aids, not otherwise listed (e.g.,
electroless copper plating)
Processing Aid
Industrial Use
Chemical substances
in industrial products
Paints and coatings; adhesives and sealants; lubricants
Use of Coatings, Paints, Adhesives, or
Sealants
Industrial Use of Lubricants
Foundries
Industrial Use
Chemical substances
in industrial products
Aerospace use in: Paints and coatings; adhesives and sealants; lubricants
and foam insulation
Commercial
Use
Chemical substances
in 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.
Textile Finishing
Installation and Demolition of
Formaldehyde-Based Furnishings
and Building/Construction
Materials in Residential. Public
a imercial Buildings, and
Other Structures
Chemical substances
in treatment products
Water treatment products
Use of Formulations containing
Formaldehyde for Water Treatment
Chemical substances
in treatment/care
products
Laundry and dishwashing products
Use of Formulations Containing
Formaldehyde in Laundry and
Dishwashing Products
Chemical substances
in construction, paint,
electrical, and metal
products
Adhesives and Sealants; Paint and coatings
Use of Coatings, Paints, Adhesives, or
Sealants
Chemical substances
in furnishing
Construction and building materials covering large surface areas,
including wood articles; Construction and building materials covering
Installation and Demolition of
Formaldehyde-Based Furnishings
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Condition of Use (COU)
Occupational Exposure Scenario
(OES) Mapped to COU
Life Cycle
Stage
Category
Subcategory
Commercial
Use
treatment/care
products
large surface areas, including paper articles; metal articles; stone, plaster,
cement, glass and ceramic articles
and Building/Construction
Materials in Residential. Public
a imercial Buildings, and
Other Structures
Chemical substances
in electrical products
Machinery, mechanical appliances, electrical/electronic articles; Other
machinery, mechanical appliances, electronic/electronic articles
Use of Electronic and Metal Products
Chemical substances
in metal products
Construction and building materials covering large surface areas,
including metal articles
Chemical substances
in automotive and fuel
products
Automotive care products; Lubricants and greases; Fuels and related
products
Use of Formulations Containing
Formaldehyde in Automotive Care
Products
Use of Automotive Lubricants
Use of Formulations containing
Formaldehyde in Fuels
Chemical substances
in agriculture use
products
Lawn and garden products
Use of Fertilizers Containing
Formaldehyde in Outdoors Including;
Lawns
Chemical substances
in outdoor use
products
Explosive materials
Use of Explosive Materials
Chemical substances
in packaging, paper,
plastic, hobby products
Paper products; Plastic and rubber products; Toys, playground, and
sporting equipment
Use of Packaging. Paoer. Plastics, and
Hobby Products
Chemical substances
in packaging, paper,
plastic, hobby products
Arts, crafts, and hobby materials
Use of Craft Materials
Chemical substances
in packaging, paper,
plastic, hobby products
Ink, toner, and colorant products; Photographic supplies
Use of Printing Ink, Toner, and
Colorant Products Containing
Formaldehyde
Photo Processing Using Formulations
Containing Formaldehyde
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Condition of Use (COU)
Occupational Exposure Scenario
(OES) Mapped to COU
Life Cycle
Stage
Category
Subcategory
Chemical substances
in products not
described by other
codes
Laboratory Chemicals
General Laboratory Use
Disposal6
Disposal
Disposal
Worker Handling of Wastes
a The repackaging scenario covers only those sites that purchase formaldehyde or formaldehyde containing products from domestic and/or foreign suppliers and
repackage the formaldehyde from bulk containers into smaller containers for resale. Sites that import and directly process/use formaldehyde are assessed in the
relevant OES. Sites that import and either directly ship to a customer site for processing or use or warehouse the imported formaldehyde and then ship to
customers without repackaging are assumed to have no exposures and only the processing/use of formaldehyde at the customer sites are assessed in the relevant
OES. For sites that may store articles or other products that are not stored in sealed containers are assessed for exposures in the Distribution in commerce COU.
h Each of the COUs of Formaldehyde may generate waste streams of the chemical that are collected and transported to third-party sites for disposal, treatment, or
recycling. Industrial sites that treat, directly discharge, or otherwise dispose of onsite wastes that they themselves generate are assessed in each associated COU
assessment. This section assesses wastes of formaldehyde sent to and disposed of at the third-party site, including by treatment or final disposition such as waste
incineration, landfilling, or underground injection.
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2 APPROACH AND METHODOLOGY
For workplace exposures, EPA considered exposures to both workers who directly handle formaldehyde
and workers designated as ONUs who do not directly handle formaldehyde but may be exposed to
vapors, particulates, or mists that enter their breathing zone while working in locations near where
formaldehyde is being used. EPA evaluated inhalation exposures to both workers and ONUs and dermal
exposures to workers only, as ONUs by definition are not expected to have direct contact with
formaldehyde. The Agency's estimates of occupational exposure presented in this document do not
assume the use of PPE; however, the effect of respiratory and dermal protection factors on EPA's
occupational exposure estimates can be explored in the Risk Evaluation for Formaldehyde -
Supplemental Information File: Occupational Risk Calculator. For more discussion on respiratory
protection and glove (PPE) protection, refer to Appendix F.
For each OES, EPA provides high-end and central tendency for inhalation exposure concentrations as
well as high-end and central tendency dermal loading.
A central tendency is assumed to be representative of occupational exposures in the center of the
distribution for a given OES from the observed dataset. For risk evaluation, it is EPA's preference to
provide the 50th percentile (median). However, if the full distribution is not known, the Agency may
assume that the mean (arithmetic or geometric), mode, or midpoint values of a distribution represents
the central tendency depending on the appropriate statistics available for the distribution.
A high-end is assumed to be representative of occupational exposures that occur at probabilities above
the 90th percentile but below the exposure of the individual with the highest exposure (
1992a). For risk evaluation, EPA provided high-end results at the 95th percentile of the available data. If
the 95th percentile is not available, EPA used a different percentile greater than or equal to the 90th
percentile but less than or equal to the 99.9th percentile, depending on the statistics available for the
distribution. If the full distribution is not known and the preferred statistics are not available, EPA
estimated a maximum or bounding estimate in lieu of the high-end.
For the inhalation exposure concentrations and ADPRs, EPA follows the following hierarchy in
selecting data and approaches for assessing occupational exposures:
1. Monitoring data:
a. Personal and directly applicable
b. Area and directly applicable
c. Personal and potentially applicable or similar
d. Area and potentially applicable or similar
2. Modeling approaches:
a. Surrogate monitoring data
b. Fundamental modeling approaches
c. Statistical regression modeling approaches
3. Occupational exposure limits (OELs):
a. Company-specific OELs (for site-specific exposure assessments; e.g., there is only one
manufacturer who provides to EPA their internal OEL but does not provide monitoring
data)
b. OSHAPELs
c. Voluntary limits (American Conference of Governmental Industrial Hygienists [ACGIH]
Threshold Limit Values [TLV], National Institute for Occupational Safety and Health
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[NIOSH] recommended exposure limits [RELs], Occupational Alliance for Risk Science
(OARS) workplace environmental exposure level (WEELs; formerly by AIHA)
Exposure metrics for inhalation exposures include acute concentrations (AC), average daily
concentrations (ADC), and lifetime average daily concentrations (LADC). AC exposures are usually
characterized as lasting no longer than a day, and for the formaldehyde assessment, it is peak exposures
lasting more than 15 minutes and less than 330 minutes used for acute inhalation risks. The ADC is the
full-shift inhalation concentration averaged over a year, which is used for chronic, noncancer inhalation
risk estimates. An ADC for sub-chronic (averaged over a month) is also calculated for sub-chronic
noncancer inhalation risk estimates. The LADC is the full-shift inhalation concentration averaged over a
lifetime, which is used for chronic, cancer inhalation risk estimates. The approach to estimating each
exposure metric is described in Human Health Risk Assessment for Formaldehyde ( 2024a)
2.1 Approach and Methodology for Process Descriptions
EPA performed a literature search to find descriptions of processes involved in each OES. Where data
were reasonably available to do so, EPA included the following information in each process description:
• total PV associated with the OES;
• name and location of sites the OES occurs;
• facility operating schedules (e.g., year-round, 5 days/week, batch process, continuous process,
multiple shifts)
• key process steps;
• physical form and weight fraction of the chemical throughout the process steps;
• information on receiving and shipping containers; and
• ultimate destination of chemical leaving the facility.
Where formaldehyde-specific process descriptions were unclear or not reasonably available, EPA
referenced generic process descriptions from literature, including relevant Emission Scenario
Documents (ESDs) or Generic Scenarios (GSs).
2.2 Approach and Methodology for Estimating Number of Facilities
To estimate the number of facilities within each OES, EPA used a combination of bottom-up analyses of
EPA reporting programs and top-down analyses of U.S. economic data and industry-specific data.
Generally, EPA used the following steps to develop facility estimates:
1. Identify or "map" each facility reporting for Formaldehyde in the 2016 and 2020 Chemical Data
Reporting (CDR) (\ ' < < \ 2020a. 20161 2016 to 2021 TRI (\ ^ \ :0221), 2015 to 2022
Discharge Monitoring Report (DMR) ( 022c) and 2017 National Emissions Inventory
(NE1) (U.S. EPA. 2022e) data to an OES. The full details of the methodology for mapping
facilities from EPA reporting programs is described in Appendix D. In brief, mapping consists of
using facility reported industry sectors (typically reported as either North American Industry
Classification System [NAICS] or Standard Industrial Classification [SIC] codes), and TRI sub-
use information to assign the most likely OES to each facility.
2. Based on the reporting thresholds and requirements of each dataset, evaluate whether the data in
the reporting programs are expected to cover most or all the facilities within the OES. If so, no
further action was required, and EPA assessed the total number of facilities in the OES as equal
to the count of facilities mapped to the OES from each dataset. If not, EPA proceeded to Step 3.
3. Supplement the available reporting data with U.S. economic and market data using the following
method:
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a. Identify the NAICS codes for the industry sectors associated with the OES.
b. Estimate total number of facilities using the U.S. Census' Statistics of US Businesses
(SUSB) data on total establishments by 6-digit NAICS.
c. Use market penetration data (e.g., market share of specific product) to estimate the
percentage of establishments likely to be using formaldehyde instead of other chemicals.
d. Combine the data generated in Steps 3 a through 3 c to produce an estimate of the number
of facilities using formaldehyde in each 6-digit NAICS code and sum across all
applicable NAICS codes for the OES to arrive at a total estimate of the number of
facilities within the OES. Typically, EPA assumed this estimate encompasses the
facilities identified in Step 1; therefore, EPA assessed the total number of facilities for the
OES as the total generated from this analysis.
4. If market penetration data required for Step 3c were not available, use generic industry data from
GSs, ESDs, and other literature sources on typical throughputs/use rates, operating schedules,
and the formaldehyde PV used within the OES to estimate the number of facilities. In cases
where EPA identified a range of operating data in the literature for an OES, EPA used stochastic
modeling to provide a range of estimates for the number of facilities within an OES. EPA
provided the details of the approaches, equations, and input parameters used in stochastic
modeling in the relevant OES sections throughout this assessment.
2.3 Identifying Worker Activities
EPA performed a literature search to identify worker activities that could potentially result in
occupational exposures. Where worker activities were unclear or not reasonably available, EPA
referenced relevant ESDs or GSs. Worker activities for each COU can be found in Section 3.
2.4 Estimating Number of Workers and Occupational Non-users
Where available, EPA used CDR data to provide a basis to estimate the number of workers and ONUs.
The CDR Rule requires manufacturers and importers under TSCA to provide EPA with information on
the production and use of chemicals in commerce. More specifically, CDR provides basic exposure-
related information including the types, quantities, and uses of chemical substances produced
domestically and imported into the United States. EPA supplemented the available CDR data with U.S.
economic data using the following method:
1. Identify the NAICS codes for the industry sectors associated with these uses.
2. Estimate total employment by industry/occupation combination using the Bureau of Labor
Statistics' Occupational Employment Statistics data (BLS OES Data).
3. Refine the BLS OES estimates where they are not sufficiently granular by using the U.S.
Census' SUSB data on total employment by 6-digit NAICS.
4. Use market penetration data to estimate the percentage of employees likely to be using
formaldehyde instead of other chemicals.
5. Where market penetration data are not available, use the estimated workers/ONUs per site in the
6-digit NAICS code and multiply by the number of sites estimated from TRI, DMR and/or NEI.
In DMR data, sites report SIC codes rather than NAICS codes; therefore, EPA mapped each
reported SIC code to a NAICS code for use in this analysis.
6. Combine the data generated in Steps 1 through 5 to produce an estimate of the number of
employees using formaldehyde in each industry/occupation combination and sum these to arrive
at a total estimate of the number of employees with exposure within the COU.
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The number of workers and ONU for each OES is described in Appendix G. For further details on the
approach and methodology used for estimating the number of workers and ONUs, refer to Appendix G.
There are uncertainties surrounding the estimated number of workers potentially exposed to
formaldehyde. First, BLS employment data for each industry/occupation combination are only available
at the 3-, 4-, or 5-digit NAICS level, rather than at the full 6-digit NAICS level. This lack of specificity
could result in an overestimate of the number of exposed workers if some 6-digit NAICS are included in
the less granular BLS estimates but are not likely to use formaldehyde for the assessed applications.
EPA addressed this issue by refining the OES estimates using total employment data from the U.S.
Census' SUSB. However, this approach assumes that the distribution of occupation types (Standard
Occupational Classification, or SOC, codes) in each 6-digit NAICS is equal to the distribution of
occupation types at the parent 5-digit NAICS level. If the distribution of workers in occupations with
formaldehyde exposure differs from the overall distribution of workers in each NAICS, then this
approach will result in inaccuracy. The effects of this uncertainty on the number of worker estimates are
unknown, as the uncertainties may result in either over or underestimation of the estimates depending on
the actual distribution.
Second, EPA's determinations of industries (represented by NAICS codes) and occupations (represented
by SOC codes) that are associated with the OES assessed in this report are based on EPA's
understanding of how formaldehyde is used in each industry. The designations of which industries and
occupations have potential exposures is a matter of professional judgement; therefore, the possibility
exists for the erroneous inclusion or exclusion of some industries or occupations. This may result in
inaccuracy but would be unlikely to systematically either overestimate or underestimate the count of
exposed workers.
2.5 Inhalation Exposure Approaches
2,5,1 Inhalation Monitoring Data
EPA reviewed workplace inhalation monitoring data collected by government agencies such as OSHA
and NIOSH, monitoring data found in published literature {i.e., personal exposure monitoring data and
area monitoring data), and monitoring data submitted via public comments. Studies were evaluated
using the evaluation strategies presented in the Draft Systematic Review Protocol Supporting TSCA Risk
Evaluations for Chemical Substances, Version 1.0: A Generic TSCA Systematic Review Protocol with
Chemical-Specific Methodologies (also called "Draft Systematic Review Protocol") ( '21b).
Exposures are calculated from the monitoring datasets provided in the sources using the discrete data.
For datasets with six or more data points, central tendency and high-end exposures were estimated using
the 50th percentile and 95th percentile. For datasets with three to five data points, central tendency
exposure was calculated using the 50th percentile and the maximum was presented as the high-end
exposure estimate. For datasets with two data points, the midpoint was presented as a midpoint value
and the higher of the two values was presented as a higher value. If the data for an OES contained only
one data point, the report presents the single exposure value. For datasets including exposure data that
were reported as below the limit of detection (LOD), EPA estimated the exposure concentrations for
these data, following EPA's Guidelines for Statistical Analysis of Occupational Exposure Data (
).
That report recommends using the ^j=- if the geometric standard deviation of the data is less than 3.0 and
if the geometric standard deviation is 3.0 or greater.
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If the 8-hour TWA personal breathing zones (PBZ) monitoring samples were not available, area samples
were used for exposure estimates. If discrete data were not available or if the discrete data were not
expected to be representative of worker exposures, EPA incorporated non-discrete data (e.g., averages,
minimums, and maximums).
For each COU, EPA endeavors to distinguish exposures for workers and ONUs. Normally, a primary
difference between workers and ONUs is that workers may handle formaldehyde and have direct contact
with the chemical, while ONUs are working in the general vicinity of workers but do not handle
formaldehyde and do not have direct contact with formaldehyde being handled by the workers. EPA
recognizes that worker job titles and activities may vary significantly from site to site; therefore, the
Agency typically identified samples as worker samples unless it was explicitly clear from the job title
(e.g., inspectors) and the description of activities in the report that the employee was not directly
involved in the scenario. Samples from employees determined not to be directly involved in the scenario
were designated as ONU samples.
OSHA Chemical Exposure Health Data
A key source of monitoring data is by OSHA during facility inspections. Air sampling data records from
inspections are entered into the OSHA Chemical Exposure Health Data (CEHD) that can be accessed
online. The database includes PBZ monitoring data, area monitoring data, bulk samples, wipe samples,
and serum samples. The collected samples are used for comparing to OSHA's PELs and STELs.
OSHA's CEHD website indicates that they do not (1) perform routine inspections at every business that
uses toxic/hazardous chemicals, (2) completely characterize all exposures for all employees every day,
or (3) always obtain a sample for an entire shift. Rather, OSHA performs targeted inspections of certain
industries based on national and regional emphasis programs, often attempts to evaluate worst case
chemical exposure scenarios, and develops "snapshots" of chemical exposures and assess their
significance (e.g., comparing measured concentrations to the regulatory limits).
EPA took the following approach to analyzing OSHA CEHD:
1. Downloaded monitoring data for Formaldehyde from 1992 to 2022. See Section 2.7 for
evidence integration notes on targeted years (05 ).
2. Organized data by site (i.e., grouped data collected at the same site together).
3. Removed data in which all measurements taken at the site were recorded as "0" or below
the LOD. EPA could not be certain the chemical of interest was at the site at the time of the
inspection (Note that sites where bulk samples were collected that indicate formaldehyde was
present were not removed from the dataset).
4. Removed serum samples, bulk samples, wipe samples, and blanks. These data are not used in
EPA's assessment.
5. Assigned each data point to an OES. EPA used a crosswalk of SIC code to NAICS code, and
then established a mapping between NAICs code to OES. In some instances, EPA was unable to
determine the OES from the information in the CEHD; in such cases, the Agency did not use the
data in the assessment. EPA also removed data determined to be likely for non-TSCA uses or
otherwise out of scope.
Peak (15-Minute) Estimates
6. Extracted 15-minute STEL Measurements. For estimating peak exposures, EPA assumes that
when OSHA inspectors measured for 15-minutes, it was for comparison to the STEL and for
activities expected to be peak exposures for the worker.
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7. Addressed less than LOD samples. EPA assumes that the sampling method is OSHA 52, and
uses the provided sample volume. Where sample volume is not provided, EPA assumes the
recommended sampling rate of 0. lL/min.
Other Short-Term Estimates
8. Extracted samples from OSHA inspectors who measured exposures from 15 to 60 minutes as
well as samples that fell between 15 and 330 minutes.
9. Addressed less than LOD samples. EPA assumes that the sampling method is OSHA 52, and
uses the provided sample volume. Where sample volume is not provided, EPA assumes the
recommended sampling rate of 0. lL/min.
Full Shift (8-Hour TWA Estimates)
10. Combined samples from the same worker. In some instances, OSHA inspectors will collect
multiple samples from the same worker on the same day (these are indicated by sample ID
numbers). In these cases, EPA combined results from all samples for a particular sample ID to
construct an exposure concentration based on the totality of exposures from each worker. In
some cases, blank samples were non-zero, and the associated samples were not used.
11. Addressed less than LOD samples. Occasionally, some or all of the samples associated with a
single sample number measured below the LOD. Because the samples were often on different
time scales (e.g., 1 vs. 4 hours), EPA did not include these data in the statistical analysis to
estimate values below the LOD as described previously in this section. Sample results from
different time scales may vary greatly as short activities my cause a large, short-term exposure
that when averaged over a full shift are comparable to other full shift data. Therefore, including
data of different time scales in the analysis may give the appearance of highly skewed data when
in fact the full shift data is not skewed. Therefore, EPA performed the statistical analysis (as
needed) using all the non-OSHA CEHD data for each OES and applied the approach determined
by the analysis to the non-detects in the OSHA CEHD data. Where all the exposure data for an
OES came from CEHD, EPA used only the 8-hour TWAs that did not include samples that
measured below the LOD to perform the statistical analysis. EPA assumes that the sampling
method is OSHA 52 and in cases where no sampling volume is provided, assumed a sampling
rate of 0.1 L/min.
12. Calculated 8-hour TWA results from combined samples. Where the total sample time was
less than 8 hours (480 minutes), but greater than 330 minutes, EPA calculated an 8-hour TWA
by assuming exposures were zero for the remainder of the shift. EPA divided the summed
products of sample duration and sample result by the sum total of field sample durations when
the summed duration exceeded 480 minutes. This calculates an extended-shift TWA exposure,
which EPA assumes is representative of 8-hour TWA exposure. EPA did consider all samples
for 8-hour TWAs that were marked "eight-hour calculation used" in the OSHA CEHD database
with no adjustment.
OSHA CEHD does not provide job titles or worker activities associated with the samples; therefore,
EPA assumed all data were collected on workers and not ONUs.
The crosswalk used for assigning OSHA CEHD data to OESs using NAICS codes is provided in
Appendix C.9. An analysis on the OSHA CEHD and the underlying assumptions and impact on
exposure estimates are provided in Appendix E. Specific details related to the use of monitoring data for
each COU can be found in Sections 3.1.1.3 through 3.30.1.3.
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2,5,2 Inhalation Exposure Modeling
As mentioned above, EPA primarily relied on monitoring data to develop inhalation exposure estimates.
Where inhalation exposures are expected for an OES but monitoring data were not reasonably available,
EPA utilized models to estimate inhalation exposures. Outputs from models may be the result of
deterministic calculations, stochastic calculations, or a combination of both deterministic and stochastic
calculations. For each OES with modeled inhalation exposures, EPA followed these steps to estimate
exposures:
1. Identify worker activities/sources of exposures from process.
2. Identify or develop model equations for estimating exposures from each source.
3. Identify model input parameter values from relevant literature sources, including activity
durations associated with sources of exposures.
4. If a range of input values is available for an input parameter, determine the associated
distribution of input values.
5. Calculate exposure concentrations associated with each activity.
6. Calculate full shift TWAs based on the exposure concentration and activity duration associated
with each exposure source.
7. Calculate exposure metrics (AC, ADC, LADC) from full shift TWAs.
For exposure models that utilize stochastic calculations, EPA performed a Monte Carlo simulation using
the Palisade @Risk software with 100,000 iterations and the Latin Hypercube sampling method.
Detailed descriptions of the model approaches used for each OES, model equations, input parameter
values, and associated distributions are provided in Appendix C.
EPA addressed variability in inhalation models by identifying key model parameters to apply a
statistical distribution that mathematically defines the parameter's variability. The Agency defined
statistical distributions for parameters using documented statistical variations where available. Where
the statistical variation was unknown, assumptions were made to estimate the parameter distribution
using available literature data, such as GSs and ESDs.
2.6 Dermal Exposure Approach
EPA only evaluated dermal exposures for workers as ONUs are not expected to directly handle
formaldehyde and therefore dermal exposure is not expected for these individuals. Formaldehyde dermal
exposure data were not reasonably available for any of the COUs considered in this assessment. As a
result, EPA modeled dermal loading using a combination (Equation 2-1) of the EPA/OPPTT 1-Hand
Dermal Contact with Liquid Model, EPA/OPPT 2-Hand Dermal Contact with Liquid Model, and
EPA/OPPT 2-Hand Dermal Immersion in Liquid Model; henceforth referred to as the Modified
EPA/OPPT 1- and 2-Hand Dermal Exposure Models. Dermal exposure to solid articles are not
quantified, as the chemical will be entrained in the article and concentrations of formaldehyde in articles
are low such that exposure will be limited.
Equation 2-1.
Where:
exp
a
s
Qu
Yder,
Dexp
S x Qu x fabs x Yderm x FT
BW
the dermal retained dose (mg/kg-day)
the surface area of contact (cm2)
the quantity remaining on the skin after an exposure event (high-end: 2.1
mg/cm2-event, central tendency 1.4 mg/cm2-event)
the weight fraction of the chemical of interest in the liquid (wt %)
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FT = the frequency of events (Default: 1 event/day)
fabs = the fraction of applied mass that is absorbed (%)
BW = the body weight (kg)
The standard model considers an assumed amount of liquid on skin during one contact event per day
(Qu\ an absorption factor (abs), surface area of the hands (S) and the weight fraction of formaldehyde
(Yderm) in the formulation to calculate a dermal dose.
As the health effect of concern for formaldehyde is the result of exposure at the point of contact, as
opposed to the chemical absorbing into the skin, the absorption factor, evaporation, body weight, and
surface area were not necessary for the calculation of dermal exposure.
The dermal loading calculation (Equation 2-2) reduces to an assumed amount of liquid on the skin
during one contact event per day adjusted by the weight fraction of formaldehyde in the liquid to which
the worker is exposed.
Equation 2-2.
Where:
D
Qu
Yden
FT
D[}ig/cm ]
2 "|
(Ji! x Yderm x FT x 1000
the dermal loading of the chemical onto the worker's skin {pLg/cm2)
the quantity remaining on the skin after an exposure event (routine, high-end: 2.1
mg/cm2 -event, central tendency 1.4 mg/cm2-event)
the weight fraction of the chemical of interest in the liquid (wt %)
the frequency of events (Default: 1 event/day)
For spray applications, EPA expects dermal exposures to be higher. In these cases, EPA calculated
dermal exposures based on a higher amount of formaldehyde remaining on skin upon immersion (high
end: 10.3 mg/cm2-event; central tendency 3.8 mg/cm2-event). Specific details of the dermal exposure
assessment for each OES can be found in Section 3, and for additional discussion of the dermal model,
refer to Appendix C.9.
The Modified EPA/OPPT 1- and 2-Hand Dermal Exposure to Liquids Models assume a single exposure
event per day based on existing framework of the EPA/OPPT 2-Hand Dermal Exposure to Liquids
Model and do not address variability in exposure duration and frequency. For this assessment, effects
from dermal exposure are acute effects. Additionally, dermal exposures to formaldehyde vapor that
might penetrate clothing and the potential for associated direct skin contact with clothing saturated with
formaldehyde vapor are not quantified exposures, which could potentially result in underestimates of
exposures. A strength of the assessment is that all data that EPA used to inform the modeling parameter
distributions have overall data quality determinations of either high or medium from EPA's systematic
review process.
2.7 Evidence Integration for Occupational Exposure
Evidence integration for the occupational exposure assessment includes analysis, synthesis and
integration of information and data to produce estimates of occupational inhalation and dermal
exposures. During evidence integration, EPA considered the likely location, duration, intensity,
frequency, and quantity of exposures while also considering factors that increase or decrease the
strength of evidence when analyzing and integrating the data. Key factors EPA considered when
integrating evidence includes the following:
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1. Data Quality. EPA only integrated data or information rated as high, medium, or low obtained
during the data evaluation phase. Data were rated through the following metrics: methodology,
geographic scope, applicability, temporal representativeness, sample size, and metadata
completeness. For example, a source may get a high data quality rating if it has an approved
methodology, data from the United States, and recently collected data. Data and information
rated as uninformative were not used in exposure evidence integration. In general, higher
rankings are given preference over lower ratings; however, lower ranked data may be used over
higher ranked data when specific aspects of the data are carefully examined and compared. For
example, a lower ranked data set that precisely matches the OES of interest may be used over a
higher ranked study that does not as closely match the OES of interest.
2. Data Hierarchy. EPA used both measured and modeled data to obtain representative estimates
(e.g., central-tendency, high-end) of the occupational exposures resulting directly from a specific
source, medium, or product. If available, measured exposure data were given preference over
modeled data, with the highest preference given to data that are both chemical-specific and
directly representative of the OES/exposure source.
a. As sufficient monitoring data were identified for formaldehyde, preference was given to
monitoring data sampled after the latest PEL update. The 8-hour TWA OSHA PEL was
updated in 1992 to 0.75 ppm from the prior PEL of 1 ppm (1987), which was an update
from the pre-1987 PEL of 3 ppm.
EPA considered both data quality and data hierarchy when determining evidence integration strategies.
The final integration of occupational exposure evidence combined decisions regarding the strength of
the reasonably available information, including information on plausibility and coherence across each
evidence stream.
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3 OCCUPATIONAL EXPOSURE ASSESSMENT
The following sections contain process descriptions, inhalation, and dermal exposure estimates for the
assessment for each COU. As previously stated, EPA provides estimates for the exposure scenario, in
which a COU could have multiple occupational exposure scenarios. When there were multiple scenarios
for one COU, EPA selected a "risk-driver" scenario for risk characterizations for the COU. The Agency
followed the steps below for selecting the representative scenario unless otherwise noted:
• For shorter term exposures, EPA selected the scenario with the highest high-end shorter term
exposure estimate;
• For dermal exposures, EPA selected the scenario with the highest high-end dermal exposure
estimate; and
• For chronic, long-term exposures, EPA selected the scenario with the highest full shift (8- or 12-
hour) central tendency exposure estimate.
3.1 Manufacturing - Domestic Manufacturing
3.1.1 Manufacturing of Formaldehyde
3.1.1.1 Process Description
Currently, most formaldehyde is manufactured using one of two methods using methanol and air as
feedstocks: a silver-catalyst-based process and a metal-oxide-catalyst-based process (Krati. I ,
Gerberich and Seaman. 2013: NICNAS. 2006:1 v « « \ t ib. ICFL 1984: IARC. 1982: NIQSH.
1981a). Both processes mix preheated air with vaporized methanol, feed the gaseous mixture into a
reactor, cool the reactor products, and then separate the products through absorption towers and
distillation columns to recover an aqueous formaldehyde solution (Gerberich and Seaman. 201
NICNAS. 2006: ICFI. 1984). The silver-catalyst-based process uses a feed that is rich in methanol and
completely converts the oxygen while the metal-oxide-based process uses a feed that is lean in methanol
and completely converts the methanol. Both processes must keep the mixture of methanol and oxygen
outside of the flammable range. Approximately 70 percent of newly installed formaldehyde production
capacity uses the metal oxide process (Gerberich and Seaman. ). Methanol arrives at the facility in
tank trucks or railroad tank cars and is transferred to a large bulk storage tank, where it is then pumped
to a methanol vaporizer (NICNAS. 2006: Dunn et at.. 1983b: Dunn et at.. 1983a: Monsanto Research
Corp. 1981). The manufacture of formaldehyde is an enclosed continuous process (NICNAS. 2006).
The silver-catalyst-based process operates the reactor at approximately atmospheric pressure and a
temperature of 450 to 650 °C (Gerberich and Seaman. 2013). The byproducts include carbon monoxide,
carbon dioxide, methyl formate, formic acid, and hydrogen (Gerberich and Seaman. l , x K 'NA.S.
2006). The separation process uses absorption, distillation, and anion exchange to produce a product of
aqueous formaldehyde solution that is up to 55 weight percent (wt%) formaldehyde and less than 1.5
percent methanol. This process can achieve an overall yield of 86 to 90 percent on a methanol basis
(Gerberich and Seaman. 2013).
The metal-oxide-based process uses metal oxide catalysts such as vanadium oxide and iron oxide-
molybdenum oxide (Gerberich and Seaman. ). The reactor operates at approximately atmospheric
pressure and a temperature of 300 to 400 °C. The byproducts include carbon monoxide and dimethyl
ether with smaller amounts of carbon dioxide and formic acid (Gerberich and Seaman. 2013: NICNAS.
2006). The separation process uses absorption and ion exchange to produce a product of an aqueous
formaldehyde solution that is up to 55 wt% formaldehyde and less than 1 percent methanol. This process
can achieve an overall yield of 88 to 92 percent on a methanol basis (Gerberich and Seaman. 2013).
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New production processes are in development, including the partial oxidation of methane and the
dehydrogenation of methanol, but no units were commercial as of 2013 (Gerberich and Seaman. 2013).
Common formaldehyde grades include formulations of 37, 44, 50, and 56 wt% (Krali. 2015; Gerberich
and Seaman. 2013; NIOSH. 1986; Dunn et at.. 1983b; Monsanto Research Corp. 19S s. \Kt I • }N2;
NIOE Ha). In the 2016 CDR, all 31 facilities that reported domestically manufacturing
formaldehyde in 2015 reported manufacturing formaldehyde in liquid form. Formaldehyde was reported
to be manufactured at concentrations of 30 to 60 wt% by 30 facilities and at a concentration of 90 wt%
or greater by one facility (I v << \ _
-------
3.1.1.2 Worker Activities
During manufacturing of formaldehyde, workers may be exposed to formaldehyde when transferring the
finished product from the separator into storage/shipment drums and during sampling. A public
comment submitted by Celanese Corporation stated the PPE required in their formaldehyde
manufacturing plant included full-face respirators, fire-resistant clothing, cut resistance gloves, safety
glasses/goggles, ear plugs, and non-permeable steel-toed boots. During specific tasks with potential for
high formaldehyde exposure, workers were reported to use APF 50 respirators; however, this may not be
representative of all manufacturing facilities (Celanese Corp. 2022). The only reported engineering
control in literature is ventilation.
ONUs include employees (e.g., supervisors, managers) at the manufacturing facility, where
manufacturing occurs, but who do not directly handle formaldehyde. Therefore, the ONUs are expected
to have lower inhalation exposures, lower vapor-through-skin uptake, and no expected dermal exposure.
3.1.1.3 Inhalation Exposure Estimates
The information and data quality valuation to assess occupational exposures during the manufacturing of
formaldehyde is listed in Table 3-3 and described in detail below. Table 3-4 summarizes the 8-hour
TWA, 12-hour TWA, 15-minute and short-term monitoring data for the manufacturing of formaldehyde.
Table 3-3. Manufacturing Inhalation Exposure Data Evaluation
Worker Activity or
Sampling Location
Data Type
Number
of
Samples
Overall Data
Quality
Determination
Source(s)
Several worker activities
described including operator,
project engineer, lab
personnel, and industrial
hygienist.
PBZ monitoring data
45
High
(Celanese Corp, 2022)
Unknown
PBZ monitoring data
31
Medium
(OSHA. 2019)
Field process operator
PBZ monitoring data
13
High
(Analytics Corporation, 2020a.
b. 2019a. b. 2018a. b. 2017b.
2016a. b)
Unknown
PBZ monitoring data
4
High
(Analytics Corporation, 2021)
Environmental health and
safety, quality control/quality
assurance, logistics,
maintenance, and operators.
PBZ monitoring data
4,401
High
(Stantec ChemRisk, 2023)
For the 15-minute data, 13 of the 16 of the worker samples were from OSHA CEHD and 3 of the
samples were from (Celanese Corp. 2022). EPA reviewed OSHA CEHD database for current and past
manufacturers of formaldehyde using facility information available in 2016 and 2020 CDR (
2020a. 2016) and a previous EPA publication ( ). For 15-minute sampling, the data used
is from two former formaldehyde manufacturers sampled in 1992. EPA also integrated recent data from
a study that measured three operators for specific tasks where the workers were equipped with APF 50
respirators (Celanese Corp. 2022). For the other shorter term data, EPA identified data in the OSHA
dataset from 4 manufacturers measured in 1992, 2000, 2015, and 2016. These samples ranged in
duration measured from 28 to 205 minutes.
For the 8-hour TWA data, 3,975 of the worker samples and 426 of the ONU samples were from a public
comment submitted by the American Chemistry Council (ACC) (Stantec ChemRisk. 2023). This data
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were collected by the ACC from 17 major U.S. formaldehyde manufacturing facilities and were
measured between 2012 and 2020. The study indicates that manufacturing data includes sites that solely
manufacture formaldehyde and sites that both manufacture formaldehyde and process formaldehyde as a
reactant. These manufacturing facilities included Celanese Corporation; therefore, EPA did not integrate
8-hour TWA sampling data from Celanese Corporation (Celanese Corp. 2022) for the 8-hour TWA
estimates for manufacturing. However, EPA used the 12-hour TWA measurements included in the study
to inform the 12-hour TWA estimates. In addition, seventeen sampling data points measured between
2016 to 2021 from Perstorp Polyols' formaldehyde department were also integrated.
For the 8-hour TWA data, it should be noted that 24 percent of the worker samples and 43 percent of the
ONU samples measured below the LOD. In addition, it should be noted that 58 percent of the greater
than 15 to less than 330-minute estimates and 11 percent of greater than 14 to less than 60-minute
worker samples are below the LOD. To estimate exposure concentrations for these data, EPA followed
the Guidelines for Statistical Analysis of Occupational Exposure Data ( a), as discussed
in Section 2.5.1.
The high-end and central tendency values for data represent the 95th and 50th percentile, respectively.
The calculated values are summarized below in Table 3-4.
Table;
5-4. Summary oi
' Inhalation Exposure Monitoring Data for Manul
'acturing OES
Exposure
Concentration
Type
Worker Exposures
Number
of
Worker
Samples
ONU Exposures
Number
of ONU
Samples
Data Quality Rating of
Air Concentration
Data
Central
Tendency
(ppm)
High-
End
(ppm)
Central
Tendency
(ppm)
High-
End
(ppm)
Full-
Shift
8-hour TWA
0.05
0.25
3,998
0.03
0.14
426
Medium to High
12-hour TWA
0.02
0.06
20
0.01
0.02
22
High
Shorter term a
15-minute
0.60
171
16
EPA did not identify short-term
data for ONUs
Medium to High
>15 to <330
minutes
0.06
0.23
12
Medium
>14 to <60
minutes
0.35
88
19
Medium to High
a One of the short-term 15-minute sample was indicated to be "accidental" as an alternate method was done that cause
exposure to heat and direct fumes. Without this sample, short-term exposures would be:
15 minutes - CT:0.48; HE: 27 ppm; >14 minutes - <60 minutes - CT:0.35; HE: 21ppm
EPA identified additional studies through our systematic review process with personal breathing zone
monitoring data for the manufacturing of formaldehyde that did not provide discrete data that could be
integrated into the inhalation estimates. Therefore, the data were not included in the exposure estimates
listed above. Overall, the monitoring data in these studies were all conducted in sites in other countries
but reported similar concentrations during manufacturing of formaldehyde. In the 2006 formaldehyde
NICNAS report, monitoring data from two Australian sites ranged from 0.1 to 0.3 ppm for operators,
maintenance workers, chemists, and loading staff monitored at their manufacturing sites. The
formaldehyde operators had 12-hour shifts while other job categories ranged from 8- to 12-hour shifts.
ECHA Q ) collected monitoring data from an unknown number of formaldehyde manufacturers
within the EU, the 90th percentile of the long-term monitoring data was 0.18 ppm (0.23 mg/m3; n = 94)
and short-term monitoring data was 0.24 ppm (0.30 mg/m; n = 39). OECD (2002) measured worker
Page 40 of 313
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exposures at German manufacturing sites in the 1990s, which was approximately between 0.016 to 0.30
ppm (0.02 to 0.37 mg/m3).
3.1.1.4 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The maximum concentration assessed for this
OES was 60 percent, based on a range of 30 to 60 percent maximum concentration reported by 30
manufacturers ( 2020a). Two manufacturers reported a maximum of 90 percent as a liquid,
which EPA expects would need to be kept at high temperatures to prevent polymerization. EPA expects
workers are more likely to have the potential for dermal contact with formaldehyde formulations below
60 percent. The calculated occupational dermal exposures for this OES are 840 |ig/cm2 as the central
tendency value and 1,260 |ig/cm2 as the high-end value.
3.2 Manufacturing - Importing
3.2.1 Import and/or Repackaging of Formaldehyde
3.2.1.1 Process Description
Import
Commodity chemicals such as formaldehyde may be imported into the United States in bulk via water,
air, land, and intermodal shipments (Tomer and Kane. 2015). These shipments take the form of
oceangoing chemical tankers, railcars, tank trucks, and intermodal tank containers. Chemicals shipped in
bulk containers may be repackaged into smaller containers for resale, such as drums or bottles.
Domestically manufactured commodity chemicals may be shipped within the United States in liquid
cargo barges, railcars, tank trucks, tank containers, intermediate bulk containers (IBCs)/totes, and drums.
Both imported and domestically manufactured commodity chemicals may be repackaged by wholesalers
for resale, such as repackaging bulk packaging into drums or bottles. The type and size of the container
will vary depending on customer requirements. In some cases, quality control samples may be taken at
import and repackaging sites for analyses. Some import facilities may only serve as storage and
distribution locations, and repackaging/sampiing may not occur at all import facilities (Tomer and Kane.
2015).
In the 2016 CDR, four facilities reported importing formaldehyde into the United States; one reported
importing formaldehyde in a liquid formulation at a concentration of 30 to 60 weight percent (wt%), one
reported formaldehyde in a liquid formulation at a concentration of 1 to 30 wt%, one reported it in a
liquid formulation at a concentration of less than 1 wt%, and the last reported it as a solid or liquid at a
concentration of 1 to 30 wt% (U.S. EPA. 2016). In the 2020 CDR, five facilities reported importing
formaldehyde in 2019, two reported importing formaldehyde as a liquid at a concentration of 30 to 60
wt%, two reported it as a liquid at a concentration of 1 to 30 wt%, and the last reported it as a liquid at a
concentration of less than 1 wt% ( 20a). The concentration of formaldehyde in an aqueous
solution (formalin) is 37 percent, and it is assumed that repackaging facilities will target this
concentration for their final product (Mirabelli et ai. 2011).
The container sizes are not included in CDR. According to NICNAS, in Australia, formalin (16-40%
formaldehyde) is imported in different-sized packages, such as 220-kg drums, 20-L drums, 22-kg
carboys, 2.5-L bottles, 500-mL bottles, and 10-mL ampoules (NICNAS. 2006). Imported formalin is
transported in pallets in full container loads or on trucks (NICNAS. 2006).
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Most repackaging of formalin or product containing formaldehyde is from 200 L drums to smaller
containers, such as 5- and 20-L containers (NICNAS. 2006). They are decanted into smaller containers
either through a pump (enclosed process) or fed via gravity. Repackaging is usually not a continuous
operation and the duration and frequency of the operation vary from site-to-site (NICNAS. 2006). Based
on data referenced in Chemical Repackaging - Generic Scenario, chemicals were repackaged at rates
ranging from 1 to 315,479 kg/site-yr, with the 50th percentile at 7,000 kg/site-yr and 95th percentile at
42,000 kg/site-yr ( 1022a). Formalin is also repacked from large storage tanks. The material is
pumped into storage tanks and transferred into various size containers using a pump and an enclosed
tubing system (NICNAS. 2006).
Figure 3-1 presents a generic flowchart for chemical repackaging scenarios and shows the different
exposure and release points in the process. Repackaging operations for liquid chemicals typically
involve pumping or pouring the product in between the original larger container into a new smaller
container ( 022a). Chemicals typically are received at repackaging sites in larger bulk
containers or drums (U.S. EPA. 2022a). Exposures and releases are expected to occur at facilities that
repackage domestically manufactured formaldehyde, as well as facilities that repackage and import
formaldehyde. Exposures and releases during repackaging are not expected to occur at facilities that
import but do not repackage formaldehyde.
Occupational Exposures:
A. Inhalation exposures to formaldehyde and dermal exposure to solids and liquids from unloading import/transport
containers.
B. Inhalation exposures to formaldehyde and dermal exposure to solids and liquids from transport container cleaning.
C. Inhalation exposures to formaldehyde and dermal exposure to solids and liquids from equipment cleaning.
D. Inhalation exposures to formaldehyde and dermal exposure to solids and liquids from loading transport containers.
Figure 3-1. Typical Release and Exposure Points During Chemical Repackaging (U.S. EPA.
2022a)
3.2.1.2 Worker Activities
During repackaging, workers are potentially exposed to formaldehyde, liquids, and during loading and
unloading of import/transport containers. Workers may also be exposed via inhalation or dermal
pathways during container and equipment cleaning. EPA did not find information that indicates the
extent of engineering controls and use of PPE by workers at facilities that repackage formaldehyde from
import/transport drums into smaller containers.
ONUs include employees (e.g., supervisors, managers) at the repackaging site who do not directly
handle formaldehyde. Therefore, the ONUs are expected to have lower inhalation exposures, lower
vapor-through-skin uptake, and no expected dermal exposure.
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3.2.1.3 Inhalation Exposure Estimates
The information and data quality evaluation to assess occupational exposures during repackaging is
listed in Table 3-5 and described in detail below. Table 3-6 summarizes the 8-hour TWA monitoring
data for the repackaging of formaldehyde and formaldehyde products.
Table 3-5. Repackaging Inha
ation Exposure Data Evaluation
Worker Activity or Sampling
Location
Data Type
Number of
Samples
Overall Data Quality
Determination
Source(s)
Unknown
PBZ monitoring data
79
Medium
("OSHA. 2019)
EPA identified one source with monitoring data applicable to this OES: OSHA CEHD for 15 sites under
the other chemical and allied product merchant wholesalers sector. For further discussion of OSHA
CEHD data, refer to Section 2.5.1.
Data were not available to estimate ONU exposures; EPA estimates that ONU exposures are lower than
worker exposures since ONUs do not typically directly handle chemicals. In lieu of ONU-specific data,
the Agency uses worker central tendency exposure results as a surrogate to estimate 8-hour TWA
exposures for ONUs.
For the 8-hour TWA data, it should be noted that 14 percent of the samples measured below the LOD.
For the shorter term data, 73 percent of the 15-minute monitoring, 50 percent of greater than 14-minute
to less than 60-minute monitoring, and 29 percent of greater than 15 minute to less than 330-minute
monitoring data at the wholesale facilities were below the LOD. To estimate exposure concentrations for
this data, EPA followed Guidelines for Statistical Analysis of Occupational Exposure Data (U.S. EPA.
1994a) as discussed in Section 2.5.1.
The high-end and central tendency values for the short-term and full shift data represent the 95th and
50th percentile, respectively. The calculated values are summarized below in Table 3-6.
Table 3-6. Summary of Inhalation Exposure JV
onitoring Data for Repackaging
Exposure
Concentration
Type
Worker
Exposures
Number of
Worker
Samples
ONU
Exposures
Number
of ONU
Samples
Data Quality
Rating of Air
Concentration
Data
Central
Tendency
(ppm)
High-
End
(ppm)
Full shift
8-hour TWA
0.09
0.13
7
0.09
0
Medium to High
Shorter term
15-minute
TWA
0.07
9.34
11
EPA did not identify
shorter term data for
workers or ONUs.
Medium
>15 to <330
minutes
0.09
1.47
49
>14 to <60
minutes
0.07
15.79
24
3.2.1.4 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The maximum concentration assessed for this
OES was 60 percent based on a range of 30 to 60 percent for processing-repackaging in the 2020 CDR
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(V S 1 V \ 2020a). The calculated occupational dermal exposures for this OES are 840 |ig/cm2 as the
central tendency value and 1,260 |ig/cm2 as the high-end value.
3.3 Processing - Reactant - [All Functions] in [All Industries]
One exposure scenario (Processing as a reactant) is used for the following group of COUs:
• Adhesives and sealant chemicals in: plastic and resin manufacturing; Wood product
manufacturing; Paint and coating manufacturing; All other basic organic chemical
manufacturing;
• Intermediate in: pesticide, fertilizer, and other agricultural chemical manufacturing;
Petrochemical manufacturing; Soap, cleaning compound, and toilet preparation manufacturing;
All other basic organic chemical manufacturing; Plastic materials and resin manufacturing;
Adhesive manufacturing; All other chemical product and preparation manufacturing; Paper
manufacturing; Paint and coating manufacturing; Plastic products manufacturing; Wood product
manufacturing; Construction; Agriculture, forestry, fishing, and hunting;
• Functional fluid in: oil and gas drilling, extraction, and support activities;
• Processing aids, specific to petroleum production in all other basic chemical manufacturing;
• Bleaching agent in wood product manufacturing; and
• Agricultural chemicals in agriculture, forestry, fishing, and hunting.
3.3.1 Processing as a Reactant
3.3.1.1 Process Description
Processing as a reactant or intermediate is the use of formaldehyde as a feedstock in the production of
another chemical product via a chemical reaction in which formaldehyde is consumed to form the
product. In the 2020 CDR, 40 submitters reported the use of formaldehyde for processing as a reactant
with a maximum reported concentration of 60 percent ( 10a). The CDR indicates that
formaldehyde is processed as a reactant in the following industrial sectors: plastics product
manufacturing; wood product manufacturing; paper manufacturing; plastics material and resin
manufacturing; all other basic organic chemical manufacturing; agriculture, forestry, hunting, and
fishing; paint and coating manufacturing; construction; adhesive manufacturing; petrochemical
manufacturing; and synthetic rubber manufacturing ( |20a). Within these industrial sectors,
formaldehyde is listed under the industrial function categories of intermediate, monomer, plasticizer,
adhesion/cohesion promoter, and "other" (used as a reactant with urea, used as a reactant with phenol
and cresols, antibacterial skin lotion, and not reasonably known or ascertainable).
Formaldehyde is used during the manufacturing of urea ( 2). This process consists of
seven major unit operations as shown in Figure 3-2 ( 95b). A formaldehyde-based reactant
(FBR) is added to molten urea or a hot urea solution to form methylenediurea (MDU). The FBR
facilitates the granulation process and improves product handling and storage. The FBR is added during
the solution concentration step shown below (TFI. 2024). Urea is primarily an agricultural product used
in fertilizer mixtures and animal feed supplements ( '5b).
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SOLUTIONS
~OPTIONAL WITH INDIVIDUAL MANUFACTURING PRACTICES
BULK
LOADING
Figure 3-2. Process Flow Diagram for the Manufacturing of Urea (U.S. EPA. 1995b)
In 1991, over 60 percent of formaldehyde in the United States that was processed as a reactant was used
to create a form of resin ( ). In the manufacturing of resins from formaldehyde,
formaldehyde arrives at the site in the form of formalin, a solution that typically consists of 37 to 40
percent formaldehyde (KIOSK. 198Id). The processing typically begins with the input components
being charged into the reactor at concentrations and temperatures necessary to meet customer
specifications (NIOSH. 198Id; Ropei ). The list of inputs will vary depending on the desired resin;
as an example, raw materials for phenol formaldehyde resins may include formalin, phenol, sodium
hydroxide, concentrated sulfuric acid, hexamethylenetetramine (HMT), ethanol, methanol, and xylene
(NIOSH. 198Id). Resin production is typically conducted in a batchwise process with a single batch
usually taking 8 to 12 hours to produce—although in some cases the batch may take anywhere from 5 to
30 hours to produce (NICNAS. 2006). The reaction mechanism to form the resin differs depending on
the type of resin being made ( ). Acetal resin, also known as polyoxymethylene, is the
general name for homopolymers of formaldehyde (Garbassi and Po. 2001).
Example Reaction Products
Urea-formaldehyde resins
Phenol-formaldehyde resins
Acetal resins
Melamine-formaldehyde resins
Chelating agents
Trimethylol propane
Acrylic esters
Hexamethylenetetramine
Pentaerythritol
1,4-butanediol
Other acetylenic chemicals
Urea-formaldehyde concentrates
4,4-methylenedianiline
Pyridine compounds and nitroparaffins
EPA does not know the specific starting concentration of formaldehyde for each process under
processing as a reactant, but it is expected to vary between different desired reaction products.
For the production of methylene diphenyl diisocyanate (MDI), formaldehyde is received at 37 percent
directly to processing/storage units from permanent piping from a supplier for one processing site
(Covestro. 2024).
A public comment from The Fertilizer Institute states that the most common FBR used to produce urea
is urea-formaldehyde concentrate (CASRN 9011-05-6) (TFI. 2024). The typical concentration for this
FBR is 60 percent formaldehyde, 25 percent urea, and 15 percent water. For the manufacturing of
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formaldehyde-based fertilizers, FBRs are received onsite in stabilized water solutions via tank trucks
that are pumped into storage. The FBRs are often stored in bulk warehouses containing up to 100,000
tons of urea. Slow-release urea solid fertilizer products are packaged in 25 to 1,000 kg bags, and triazone
fertilizer products are packaged in 275-gallon totes. EPA expects formaldehyde to arrive as a liquid in
tank trucks, drums, or rail cars received directly from manufacturing sites.
3.3.1.2 Worker Activities
When processing formaldehyde as a reactant, workers are potentially exposed to formaldehyde during
unloading of raw materials, the drumming of finished products, and changing of ventilation filters (Dow
Chemical. 2017c). Some expected PPE and engineering controls in a facility processing formaldehyde
as a reactant include ventilation and respirators (Dow Chemical. 2017c) (Covestro. 2024). One study
reported that workers wore Ansell II gloves, safety glasses and a face shield while unloading formalin
( 30M. 2019). Another source indicated the use of chemical resistant gloves and suit with
respirators(('ovcstro. 2024). Use of the PPE and engineering controls may vary between tasks. A public
comment indicates that processes may occur outdoors and in closed systems. Workers may be exposed
during sample collection, filter changing, and connecting/disconnecting railcars. In addition, workers
perform a nitrogen purge on the connections prior to each task (Dow Chemical. 2024).
Another site indicated the use of permanent piping systems from their supplier of formaldehyde, such
that no unloading or loading of formaldehyde occurs, as well as no sampling or filtration (Covestro.
2024).
ONUs include employees (e.g., supervisors, managers) at the processing as a reactant site who do not
directly handle formaldehyde. Therefore, ONUs are expected to have lower inhalation exposures, lower
vapor-through-skin uptake, and no expected dermal exposure.
3.3.1.3 Inhalation Exposure Estimates
The information and data quality evaluation to assess occupational exposures during processing as a
reactant is listed in Table 3-7 and described in detail below. Table 3-8 summarizes the monitoring data
for the processing of formaldehyde as a reactant.
EPA integrated 293 samples from the OSHA CEHD database. These sites were attributed to the OES
from the provided NAICS codes. The NAICS codes used most for this OES were Plastic Material and
Resin Manufacturing, Adhesive Manufacturing, Petrochemical Manufacturing, and All Other
Miscellaneous Chemical Product and Preparation Manufacturing. The full crosswalk of NAICS to OES
used for integration of OSHA CEHD data is provided in Appendix D.
EPA integrated a total of 296 peak and full shift samples from industry submitted information at U.S.
facilities from 2012 to 2023, as indicated in Table 3-7. An integrated dataset of existing monitoring data
were provided for two facilities indicated to be processing formaldehyde as a reactant (Stantec
ChemRisk. 2023). The study provided 51 worker and 41 ONU full shift samples (Stantec ChemRisk.
2023). The dataset also included monitoring data for sites that both manufacture and process
formaldehyde as a reactant, those data was incorporated into the Manufacturing of formaldehyde OES.
From one manufacturer, EPA received data specific to the workers and associated activities during
processing as a reactant, which were then integrated into this OES. This study included 50 sampling
measurements including 8- and 12-hour TWA measurements for workers (Celanese Corp. 2022). That
dataset included measurement of a range of job categories involved in formaldehyde processing.
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EPA integrated two full shift samples from a study completed at a formaldehyde resin production
factory in Portugal. Viegas (2013) monitored worker exposure for 6 to 7 hours during impregnation and
quality control activities. Based on the information in the study, EPA assumes the data is representative
of full shift exposures. All monitored data were below the detection limit.
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Table 3-7. Processing as a Reactant Inhalation Exposure Data Evaluation
Worker Activity or Sampling Location
Data Type
Number
of
Samples
Overall Data
Quality
Determination
Source(s)
Various activities during resin manufacturing such as
operator of impregnation machine and resin sample
analysis
PBZ monitoring data
2
High
(Vleeas et al., 201 j)
Various activities such as operator, lab operator, and
control room board operator
PBZ monitoring data
50
High
(Celanese Corn. 2022)
Drumming finished products and changing filters, pulling
process samples, unknown worker activities during resin
manufacturing
PBZ monitoring data
25
Medium to
High
(Dow Chemical. 2019a. b. c. 2017a. c. d)
Unloading railcar, sampling, and operators
PBZ monitoring data
32
High
(Dow Chemical. 2024)
Operator, assistant operator, power house operator,
mechanic, insulator and E/I technician
PBZ monitoring data
57
High
(Analytics Corporation. 2020a. b. 2019a. b.
2018a. b. 2017b. . )
Operator during blending operators
PBZ monitoring data
5
High
(FRM Risk. 2019)
Exchanging drums of formalin, Lab technician
PBZ monitoring data
3
High
( 1.2019)
Environmental health and safety, quality control/quality
assurance, logistics, maintenance, and operators
PBZ monitoring data
92
High
(Stantec ChemRisk. 2023)
Unknown
PBZ monitoring data
293
Medium
(OSHA. 2019)
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Dow Chemical provided workplace monitoring data from 2016 to 2019, mostly short-term and 15-
minute samples as workers change filters, took samples, and loaded finished products (Dow Chemical.
2019a. b, c, JO I j, c, d). In addition, Dow Chemical provided 12 8-hour samples monitored in 2023
during the unloading rail cars and 20 short-term samples for workers collecting samples and while
disconnecting the rail cars (Dow Chemical. 2024). EPA also integrated 57 samples expected to be taken
during reactant processes at Perstrop polyols (Analytics Corporation. 2020a. b, 2019a. b, 2018a. b,
2017b. 2016a. b).
Data was obtained from two industrial hygiene studies from two U.S. facilities (AECOM. 2019; FRM
Risk. 2019). FRM Risk (2019) monitored one blend operator while handling supersacks of
paraformaldehyde, a reaction product of formaldehyde. Three 15-minute samples were monitored during
blending operations at the same site. For this site, the workers wore full facepiece air purifying respirator
(APF 50) during the monitored 15-minute activities. AECOM (2019) measured one 15-minute sample
for a worker unloading a drum of formalin and one 15-minute and a 98-minute sample for a lab
technician conducting quality control tests. EPA assumes that the activities measured for these studies
would be representative of the expected activities to occur at sites that process formaldehyde as a
reactant.
Data were not available to estimate 12-hour TWA ONU exposures; EPA estimates that ONU exposures
are lower than worker exposures since ONUs do not typically directly handle chemicals. In lieu of
ONU-specific data, the Agency uses worker central tendency exposure results as a surrogate to estimate
exposures for ONUs.
For the 8-hour TWA data, it should be noted that 7 percent of the worker samples and 56 percent of the
ONU samples measured below the LOD, respectively. For the 15-minute worker data, 36 percent of the
samples were below the LOD. For the greater than 15-minute to less than 330 minute worker data, 22
percent of the samples were below the LOD. For samples collected for 15 minutes but less than 60
minutes, 33 percent of the samples were below the LOD. To estimate exposure concentrations for these
data, EPA followed the Guidelines for Statistical Analysis of Occupational Exposure Data (U.S. EPA.
1994a). as discussed in Section 2.5.1.
The high-end and central tendency values for the data represent the 95th and 50th percentile,
respectively. The calculated values are summarized in Table 3-8.
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Table 3-8. Summary of Inhalation Exposure Monitoring Data for Processing as a Reactant
Exposure
Concentration
Type
Worker Exposures
Number
of Worker
Samples
ONU Exposures
Number
of ONU
Samples
Data Quality
Rating of Air
Concentration
Data
Central
Tendency
(ppm)
High-
End
(ppm)
Central
Tendency
(ppm)
High-
End
(ppm)
Full shift
8-hour TWA
Exposure
Concentration
0.05
0.81
202
0.01
0.03
41
Medium to High
12-hour TWA
Exposure
Concentration
0.02
0.15
33
0.02
0
High
Shorter term
15-minute
0.15
3.13
96
EPA did not identify short-
term data for ONUs
Medium to High
>15 to <330
minute
0.10
1.80
184
Medium to High
>14 to <60
minute
0.15
3.27
134
Medium to High
EPA identified additional studies with PBZ monitoring data for the processing of formaldehyde as a
reactant that lacked the discrete data that could be incorporated into the inhalation estimates. These data
were not included in the exposure estimates listed above. In the 2006 formaldehyde NICNAS report,
monitoring data from an Australian resin manufacturing site ranged from 0.1 to 2.0 ppm for various
worker activities such as resin operators, laboratory staff, tanker unloading, and maintenance workers.
The resin operators and chemists had 12-hour shifts while other job categories ranged from 8- to 12-
hour shifts. Plant operators, technical personnel, and maintenance workers also had short-term
monitoring data (NICNAS. 2006). ECHA (2019) collected monitoring data from an unknown number of
sites involved in resin manufacturing within the EU, the 90th percentile of the long-term monitoring data
was 0.37 mg/m3 (n = 116) and short-term monitoring data was 0.64 mg/m3 (n = 17).
Four other studies monitored facilities outside the United States at sites that produce formaldehyde-
melamine resins, the data ranged from 0.033 to 5.6 ppm for full shift worker exposures (Zendehdel et
at.. 2017; Bassie et at.. JO I > Seow et at.. 2015; Zhang et at.. 2010). Three of the facilities were located
in China and one was in Iran. Armstrong (2001) measured worker exposures to formaldehyde at an
adhesive manufacturing facility in Malaysia, the arithmetic mean was 0.43 ppm.
3.3.1.4 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The maximum concentration identified for this
OES was 60 percent based a maximum range of 30 to 60 percent reported for processing as a reactant in
the 2020 CDR (U.S. EPA. 2020a). The calculated occupational dermal exposures for this OES are 840
|ig/cm2 as the central tendency value and 1,260 |ig/cm2 as the high-end value.
3.4 Processing - Incorporation into an Article - Finishing Agents in
Textile, Apparel, and Leather Manufacturing
EPA has evaluated one exposure scenarios for this COU:
• Textile finishing
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3,4,1 Textile Finishing
3.4.1.1 Process Description
One of the formaldehyde's uses under incorporation is as a finishing agent in textile processing (U.S.
20b; NICNAS. 2006). Formaldehyde can be either used alone, together with other reagents such
as softeners or wetting agents, or in the form of simple formaldehyde derivatives CNIQS 1c;
Hovding. 1959). Resins containing formaldehyde are used as cross-linking agents and can impart
beneficial characteristics upon fabric such as wear and crease resistance, water repellency, increased
fabric resistance, and aiding in dye fixation (NICNAS. 2006; Comwell. 1988; NIOSt\ l * 4a, 1981c).
This COU was not reported in the 2020 CDR; however, information from the 2016 CDR indicates that
formaldehyde is used as a finishing agent in textiles, apparel, and leather manufacturing (
2016). Formaldehyde content in raw materials is typically 37 percent, while end products generally
range from 0.01 to 2 percent (Rovira and Domingo. 2019; Patankar et at.. 2015; Greeson et at.. JO I J;
NICNAS. 2006; Baiai. 2002; Schever et at.. 2001; Hovding. 1961).
Textile finishing can be divided into three main steps: fabric pretreatment (e.g., washing, bleaching, de-
sizing); coloring; and functional finishing (OECD. 2004a; Bendix Coi )). Formaldehyde is only
included in the functional finishing. During the finishing process, resins containing formaldehyde are
combined with catalysts and cured in ovens at high temperatures to form the "permanent-press"
treatment of fabrics. "Several varieties of resins and catalysts are used in the textiles industry. Their
application depends to a large extent on the effects desired in the finished product" (NIQSH. 1974b).
Such treated fabrics may be cut, bundled, then sewn to assemble a garment at the same site or sold to
downstream users for these processes (Burton and Monestersky. 1996; Eclu_J_v^^3).
Formaldehyde has also been identified as a preservative, finishing agent, and fixing agent in leather
tanning (U.S. EPA. 2020b; Cuadros et at.. 2016; NICNAS. 200 , I v « « \ 2001). Tanning is a general
term for the processing steps involved in converting animal hides or skins to leather (OECD. 2004a).
This COU was not reported in the 2020 CDR; however, information from the 2016 CDR indicates that
formaldehyde is used as a finishing agent in textiles, apparel, and leather manufacturing (
2016). Formalin containing 10 to 37 percent formaldehyde is used in leather tanning; however, the
formalin is diluted into a 1:10 working solution before use (NICNAS. 2006). Formaldehyde
concentrations in the final leather articles are typically less than 1 percent (NICNAS. 2006). One source
indicates that the concentrations of formaldehyde in leather articles range between 4.5 to 414 mg
formaldehyde per kg leather (Cuadros et at.. ).
According to the ESD on Leather Processing, hide and skins that are flayed at abattoirs may be cured,
chilled, or cooled before transferring to tanning facilities (OECD. 2004a). The types of hides most often
used in tanning processes are from cattle, sheep, and pigs. At tanning facilities, the production process
typically begins with hide and skin storage and beamhouse operations, which prepare the raw material
for tanning. Preparation may involve trimming, soaking, unhairing, liming, and fleshing (OECD. 2004a;
001).
The most common tanning processes are chromium tanning or vegetable tanning (OECD. 2004a; U.S.
01). Chromium tanning typically utilizes a one-bath process which takes place in large rotating
vessels for approximately 4 to 24 hours. Vegetable tanning is used in the production of heavy leathers or
sole leathers and may take anywhere from 1 day (in drums) to 6 weeks (in pits) to complete. The hide is
strung on frames in large vats containing tannin. The hides are then transferred to different bins
containing an increasing amount of tannin until the extract has penetrated the pelt (OECD. 2004a; U.S.
Page 51 of 313
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01). In the case of white sheepskin tanning, commercial grade formaldehyde (11%) is added to
the depickled skins in a drum and allowed to sit overnight (Hernon. 1981). Tanning may be followed by
draining, "sammying," or shaving to reduce moisture content. Mechanical action may occur to adjust the
thickness of the hide ( ; 20011
Post-tanning processes typically involve neutralization, washing, re-tanning, dyeing, and fatliquoring
(OECD. 2004a). This generally takes place in the same vessel. Following post-tanning, mechanical
finishing operations such as staking, buffing, polishing, and plating/embossing may take place. Surface
coats are typically applied to meet customer requirements (OB 04a).
3.4.1.2 Worker Activities
For finishing processes, workers are potentially exposed to formaldehyde in textile finishing agents
during unloading and transferring product, transport container cleaning, and machine operation (OECD.
2017). Workers may connect transfer lines or manually unload chemicals from transport containers into
finishing equipment or storage. Dermal exposure is expected for both automated and manual unloading
activities. Workers may experience inhalation and dermal exposure to formaldehyde while rinsing
containers used to transport finishing agents. Workers may also be exposed to formaldehyde present in
the curing oven during removal of treated goods after batch processes or during handling of finished
rolls of material. All of these activities are all potential sources of worker exposure through dermal
contact and inhalation of formaldehyde present in liquid finishing agents (OECD. 2017).
For the final steps of the process, workers may be exposed from formaldehyde off-gassing from the pre-
cured permanent press fabrics (Eciu h">l>3). These include exposures during sewing, cutting, or
assembling garments. According to the ESD on the Use of Textile Dyes, workers at sites that use textile
finishing agents may wear proper chemical-specific PPE, including safety glasses, goggles, aprons,
respirators, and/or masks ( ). One apparel manufacturer installed roof-top ventilators (Echt.
1993). EPA did not find information that indicates the extent of engineering controls and the use of PPE
by the workers at facilities that use textiles finishing agents in the United States.
Workers are potentially exposed to formaldehyde during leather tanning from performing finishing
operations such as conditioning, staking, buffing, finishing, plating, measuring, or grading (Stern et at..
1987). EPA did not find information that indicates the extent of engineering controls and use of PPE by
workers at facilities that perform leather tanning operations.
ONUs include employees who work at the sites where textile finishing agents are used, but who do not
directly handle chemicals and are, therefore, expected to have lower inhalation exposures and are not
expected to have dermal exposures through contact with liquids or solids. ONUs for this scenario
include supervisors, managers, and other employees who may be in the finishing area but do not perform
tasks that result in the same level of exposure as those workers who engage in tasks related to the use of
textile finishing agents.
3.4.1.3 Inhalation Exposure Estimates
The information and data quality valuation to assess occupational exposures during textile finishing is
listed in Table 3-9 and described in detail below. Table 3-10 summarizes the monitoring data for the use
of formaldehyde in textile finishing.
For monitoring data specific to leather tanning, EPA searched the OSHA CEHD database under NAICS
code 316110 - Leather and Hide Tanning and Finishing and identified three sites. For two of the three
identified sites, upon further review, EPA concluded that those sites were not involved in leather
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tanning. For short-term exposures, the Agency identified four data points (1.75 to 2.3 ppm) from the
single site measured in the Spring of 1992. However, no full shift estimates were available. EPA then
searched for data prior to 1992, which did identify two data points sampled in 1988 for the SIC code
3111 leather tanning and finishing. The 8-hour TWA of these samples were 0.99 and 0.27 ppm. Given
the limited and relatively older data available for leather tanning, EPA considered, for the condition of
use, textile finishing to characterize the exposures under this COU. The activities that the Agency expect
between leather tanning and textile finishing are similar; therefore, EPA estimates exposures for textile
finishing to be sufficient to represent the condition of use.
Table 3-9. Textile Finishing Inhalation Exposure Data Evaluation
Worker Activity or
Sampling Location
Data Type
Number of
Samples
Overall Data
Quality
Determination
Source
Sewer, cutter, and bundler
during sportswear
manufacturing
PBZ monitoring
data
8
High
(Edit. 1993)
Sewer, bundler, inspector,
cutter, and supervisor at a
knitting mill
PBZ monitoring
data
14
High
(Burton and
Monestersky.
1996)fl
Unknown
PBZ monitoring
data
485
Medium
(OSHA. 2019)
a All samples were below the limit of quantification but above the LOD.
A majority of the 8-hour TWA worker samples were from OSHA's CEHD in the textile and fabric mills
and textile product mills sectors. For further discussion of the approach taken with OSHA CEHD data,
refer to Section 2.5.1. All other 8-hour TWA samples came from two NIOSH HHEs investigating
exposure to formaldehyde at a sportswear manufacturing facility and a knitting mill (Burton and
Monestersky. 1996; Edit h">l>3). The dataset included measurement of a range of workers involved in
garment manufacturing. The shorter term worker samples are all from OSHA CEHD for textile and
fabric mills and textile product mills sectors.
Data were not available to estimate ONU exposures; EPA estimates that ONU exposures are lower than
worker exposures because ONUs do not typically directly handle chemicals. In lieu of ONU-specific
data, EPA used worker central tendency exposure results as a surrogate to estimate full-shift exposures
for ONUs.
It should be noted that 11 percent of the 8-hour TWA samples measured below the LOD, 69 percent of
the 15-minute samples, 23 percent of 15 minutes to 330 minutes samples, and 63 percent of the samples
measured between 15 and 60 minutes were below the LOD. To estimate exposure concentrations for
these data, EPA followed the Guidelines for Statistical Analysis of Occupational Exposure Data (U.S.
94a). as discussed in Section 2.5.1. All of the samples for the 12-hour data were between the
minimum detectable concentration and minimum quantifiable concentration, these values were not
adjusted.
The high-end and central tendency values for data represent the 95th and 50th percentile, respectively.
The calculated values are summarized in Table 3-10.
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Exposure
Concentration Type
Worker Exposures
Number
of
Worker
Samples
ONU
Exposures
"ft
Data Quality
Rating of Air
Concentration
Data
Central
Tendency
(ppm)
High-
End
(ppm
Full shift
8-hour TWA
0.06
0.41
141
0.06
Medium to High
12-hour TWA
0.04
0.04
2
0.04
High
Short-term
15-minute TWA
0.07
0.88
80
EPA did not
identify short-
term data for
ONUs
Medium to High
>15 to <330 minute
0.08
0.59
277
Medium to High
>14 to <60 minute
0.07
0.84
110
Medium to High
A public comment provided discrete monitoring data at U.S. sites for processing-incorporation into
article (Stantec ChemRisk. 2023). EPA did not integrate the data as no additional process or worker
activity information was provided to attribute to individual occupational exposure scenarios (e.g., type
of produced article). The reported 50th percentile and 95th percentile full shift exposures were 0.08 and
0.313 ppm, respectively. These estimates generally fit within the range estimated for this exposure
scenario.
3.4.1.4 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The COU for textile finishing OES was not
reported in 2020 CDR, but was reported in 2016 CDR. The maximum concentration identified for
processing-incorporation into an article- textiles, apparel, and leather manufacturing was 1 to 30 percent
( 2020a). However, formaldehyde content in raw materials is typically 37 percent for textile
processing, while end products generally range from 0.01 to 2 percent (Rovira and Domingo. 2019;
Pataukar et at.. -01 * V'^son et at.. 2012; NICNAS. 2006; Baiai. 2002; Schever et at.. 2001; Hovding.
1961). The weight concentration of 37 percent was used. The calculated occupational dermal exposures
for this OES are 518 |ig/cm2 as the central tendency value and 777 |ig/cm2 as the high-end value.
3.5 Processing - Incorporation into an Article - Paint Additives and
Coating Additives Not Described by Other Categories in
Transportation Equipment Manufacturing
EPA has evaluated two exposure scenarios for this COU use:
• Use of coatings, paints, adhesives, or sealants (non-spray applications); and
• Use of coatings, paints, adhesives, or sealants (e.g., spray or roll).
3.5.1 Use of Coatings, Paints, Adhesives, or Sealants
3.5.1.1 Process Description
Formaldehyde containing resins used as adhesives in wood and engineered wood product manufacturing
as well as in tire manufacturing were assessed in Section 3.7.1 and Section 3.6.1, respectively (USTMA.
2019; Jahromi. 2005; Williams. 2002).
Adhesives and Sealants
Public comments indicate that formaldehyde is present in trace amounts in most raw materials used for
adhesives and sealants, including those used in the aerospace industry (NASA. 2020; U _ JO rs; U \
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2019). These comments indicated that concentration of formaldehyde in the final product may range
from 0.1 to 1 percent, although formulators expect the actual concentration of formaldehyde to be lower
(ACA. 2019). However, submitters in the 2020 CDR indicated 1 to 30 percent maximum concentration
for two-component glues (U.S. EPA. 2020a).
EPA did not identify formaldehyde-specific process information; however, according to the ESD on the
Use of Adhesives, a typical process begins with liquid formulations being manually poured from
transport containers directly into a coating reservoir (OECD. 2015b). Solid formulations received are
loaded directly into dispensing equipment. The application procedure depends on the type of adhesive or
sealant formulation and the type of substrate. Typically, the formulation is loaded into the application
reservoir or dispensing equipment and applied to the substrate via spray, roll, curtain, syringe, or bead
application. A diagram of the adhesive application process is shown below in Figure 3-3 (OECD.
2015b).
O = Occupational Exposures:
A. Inhalation to volatilized formaldehyde and dermal exposure to adhesives during container cleaning
B. Inhalation to volatilized fonnaldehyde and dermal exposure during equipment loading/container unloading
C. Inhalation to volatilized formaldehyde and dermal exposure during equipment cleaning
D. Inhalation to volatilized formaldehyde or mist (spray application) aiid dermal exposure during application
E. Inhalation exposure to volatilized fonnaldehyde during solvent evaporation
Figure 3-3. Typical Release and Exposure Points for the Use of Adhesives Containing
Formaldehyde (OECD. 2015b)
Roll coating is typically used for two-dimensional objects that can be wound, such as tapes (OECD.
2015b). During roll coating, a continuous spinning roller brush applies the adhesive to the moving
substrate. A roller carries the adhesive from the reservoir to the substrate. A blade may be used to
control the thickness of the adhesive. Variants of roll coating include direct, reverse, off-set, and gravure
(OECD. 2015b).
During curtain coating, the adhesive is applied as the substrate passes through a liquid curtain (OECD.
2015b). A curtain is formed by the adhesive issued from precision die, typically 20 to 30 cm above the
substrate. A blade may be used to control the thickness of the adhesive. Additional adhesive not
transferred to the substrate is dripped into collection tunnels and either recycled to the feed reservoir or
disposed of (OECD. 2015b).
Syringe or bead application may be used when the adhesive only needs to be applied to specific
locations, such as electronic circuit boards or furniture manufacturing (OECD. 2015b). During
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application, the adhesive is either extruded from a glue gun or squeezed out of a tube or syringe as a
liquid onto the substrate. The adhesive may be applied in long lines or beads or applied in small amounts
to an exact location (OECD. 2015b).
All application types may be manual or automated (OB ). After application, the adhesive or
sealant is allowed to dry or cure (( ) Transport containers may be cleaned off-site by a third
party. EPA did not identify formaldehyde-specific application methods; therefore, EPA assumes any of
the above methods may be used.
Use of Paint and Coatings
According to American Coating Association (ACA), formaldehyde is present in trace amounts in most
raw materials used in paints, coatings, sealants, and adhesives with a range from 0.1 to 1 percent (
2019). A public comment indicates the use of formaldehyde in a wide range of coatings, such as
primers, topcoats, varnishes, lacquers, and specialty coatings ( ). Formaldehyde is in synthetic
latex resins and is also found in fluorescent pigments. However, submitters in the 2020 CDR indicated
30 to 60 percent maximum concentration for solvent based paints ( 20a). One submitter
reported downstream use of formaldehyde in liquid, spreadable coatings used for playgrounds (The Toy
Association. 2024). EPA expects sites may receive concentrated formulation and dilute and mix on site
for their desired needs.
EPA did not identify formaldehyde-specific process information; however, several sources provide
generic process information. The formulation typically arrives at the facility as a liquid in 55-gallon
drums and is loaded into the application reservoir (OECD. 2009b; Kinnes and Mortimer. 1999). In
certain industries such as the aerospace industry, surface preparation is required which involves
stripping and repainting. The paint or coating may be applied to the substrate via spray, roller, brush,
dip, or flow and curtain coating system application (OEt O 1 I b, « I • }N8). In general, applications
may be manual or automated. The first coat applied may be an adhesive promoter, which increases
surface area on the part to promote adhesion of the subsequent coats (Kinnes and Mortimer. 1999).
In roll or curtain coating, the formulation is fed to the application reservoir via feed lines. During roll
coating, a roller picks up the coating from a tray that is transferred to an application roller. In dry booths,
the excess paint may be collected using a carton or fiber filter (OEa < * aaiasaari et at.. 2004).
In the case of decorative coatings, brush and roller application are the primary methods used. Following
application, the paint or lacquer is allowed to cure or dry. In curing, the resin forms a solid film through
a chemical reaction. The curing process may involve air drying, baking, or radiation curing (OECD.
2009b). A diagram of the radiation curable application process is shown below in Figure 3-4 (
).
Page 56 of 313
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Disco sal
© (?) R-aw Material
Sampling
*Cy = Occupational Exposures:
A. Inhalation and demial exposure to liquid formaldehyde during unloading.
B. Inhalation and demial exposure to liquid formaldehyde during sampling activities.
C. Inhalation and dermal exposure to liquid formaldehyde during container cleaning.
D. Inhalation and dermal exposure to liquid formaldehyde during coating application.
E. Inhalation and demial exposure to liquid formaldehyde during equipment cleaning.
Figure 3-4. General Radiation Curable Coating Process (OECD, 2011b)
Formaldehyde is also present in waxes used to coat cardboard caulking tubes and composite cans
(Kinnes. 1990). The concentration of formaldehyde in the wax is unknown. The cans are automatically
transferred to the auto wax unit from the production lines. The wax is preheated with mineral oil in a 55-
gallon drum and pumped to a reservoir in the wax unit. The wax is then applied via two duplex spray
heads into the open end of the can (Kinnes. 1990).
Paint and Coating Additives in Transportation Equipment Manufacturing
Information from a NIOSH HHE indicates that formaldehyde is incorporated into paints and coatings
used in the manufacture of plastic automotive fascia (front and rear bumpers) (Kinnes and Mortimer.
1999).
Coatings are shipped to fascia manufacturing facilities in 55-gallon drums (Kinnes and Mortimer. 1999).
Coatings are stored and prepared in a paint kitchen, which is a separate building attached to the main
facility. The coatings are conveyed to a robotic paint line in the main facility through carrier lines from
pneumatic mixing totes located in the paint kitchen. After the fascia is molded, they are placed on the
robotic paint line. The part is sprayed with three different coats—an adhesive promoter, base coating,
and clear coating. After the parts are painted, they are cured in an oven, allowed to cool, then prepared
for shipment to an automotive assembly facility (Kinnes and Mortimer. 1999).
Automotive Industry
Spray application of paints and coatings is utilized in the automotive refinishing industry (OECD,
201 la). Liquid coating formulations typically arrive at refinishing facilities in 1-quart to 5-gallon
containers. Various coating products such as hardeners, reducers, activators, atomizing agents, or
colorants may be blended into their final formulations according to the paint manufacturer's
specifications before application. Primers, clearcoats, and basecoats are typically mixed by hand. After
mixing, the coatings are metered or poured by hand into a mixing cup or other apparatus, and then
transferred to a spray gun cup. The primer is the first coating applied to the vehicle (OECD, 201 la).
Primer sealer may be applied if the vehicle is new, otherwise, the vehicle is structurally repaired, and a
Page 57 of 313
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high-solids surfacer is sprayed. The vehicle is lightly sanded and wiped down after primer application
(OECD. 2011a: Heitbrink et al.. 1993V
After priming, the basecoat color and clearcoat are applied and cured (OECD, 201 la). Conventional
spray guns that use high-pressure and high-volume, low-pressure (HVLP) spray guns are the most
common application tools. Both types have a mounted cup to hold the coating and are connected to a
pressurized air supply via a hose. The pressurized air atomizes the coating formulation into a spray that
is applied to the vehicle surface. The automotive industry typically uses enclosed automated spray
application with minimal fugitive emissions. Following application, each layer of coating is dried or
cured by air drying, a heated paint booth, or portable heat sources. Spray guns may be cleaned manually
or with a cleaning system. For a diagram of the process as well as typical release and exposure points
during the application of paints and coatings in the automotive refinishing industry, see Figure 3-5
( 2 ) v-V Process equipment residues (mixing cup and spray gun) Overspray
W on booth fl.
T
J
dust settled
on booth floor/walls
o =
Environmental Releases:
0=<
1. Container residue from formaldehyde transport container
disposed to incineration or landfill.
2. Process equipment (mixing cup, spray gun, spray booth
floors/walls) cleaning residues disposed to incineration or
landfill.
3. Oversprayed formaldehyde mists/particles captured within spray
area and other controls (e.g., diy filters) disposed to incineration
or landfill.
4. Oversprayed formaldehyde mists/particles not captured by
emission controls and vented to outside air.
= Occupational Exposures:
A. Dermal exposure from unloading/mixing liquid formaldehyde into final
coating, as sprayed.
B. Dermal exposure to cured/solid or liquid formaldehyde during container
cleaning.
C. Dermal exposure to fmal mixed liquid formaldehyde during manual
transfer from mixing cup to spray gun.
D. Dermal exposure to final mixed liquid formaldehyde during equipment
cleaning of mixing cup, spray gun, and spray booth floors/walls.
E. Inhalation and dermal exposure to solid/liquid formaldehyde particulates
(i.e., overspray mist) during spray application.
Figure 3-5. Automotive Refinishing Spray Coating Processes (OECD, 2011a)
3.5.1.2 Worker Activities
Workers are potentially exposed to formaldehyde during coating, paints, adhesives, and sealant during
loading/unloading transport containers, equipment and container cleaning, application of coatings, and
sampling activities (OECD, 2015b, 2011b). Literature sources stated common engineering controls
during use of coatings, paints, adhesives, or sealants to be general and local exhaust ventilation (Methner
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et ai. 2014; Ceballos and Burr. 2011). EPA did not identify any information to indicate the extent to
which workers used PPE in use of coatings, paints, adhesives, and sealants.
Only one literature source identified an engineering control in positive pressure ventilated spray booths
(Parsons Engineering Science. 1997). EPA did not identify the extent to which workers used PPE at
spray application facilities.
ONUs include employees (e.g., supervisors, managers) at sites that use coating, paints, adhesives, or
sealants who do not directly handle formaldehyde. Therefore, ONUs are expected to have lower
inhalation exposures and no expected dermal exposure.
3.5.1.3 Inhalation Exposure Estimates (Spray or Unknown Application)
The information and data quality valuation to assess occupational exposures during use of formulations
containing formaldehyde for spray or unknown applications (e.g., spray or roll) is listed in Table 3-11
and described in detail below. Table 3-12 summarizes the 8-hour TWA monitoring data for use of
formulations containing formaldehyde for spray applications.
Table 3-11. Use of Formulations Containing Formaldehyde for Spray or Unknown Applications
e.g., Spray or Roll) Inhalation Exposure Data Evaluation
Worker Activity or
Sampling Location
Data Type
Number of
Samples
Overall Data Quality
Determination
Source
Unknown
PBZ monitoring data
1,093
Medium
(OSHA. 2019)
Spray painting of lighting
components for aerospace
products
PBZ monitoring data
2
High
(Parsons Engineering
Science, 1997)
EPA identified discrete monitoring data for peak and full shift exposures for paints, coatings, adhesives
and sealants only from OSHA and Parsons Engineering Science (1997). Of the 213 8-hour TWA
samples available, 210 were from OSHA's CEHD, which does not provide worker activities or
additional process information. EPA expects a wide variety of industries may be using formaldehyde in
paints, coatings, adhesives, or sealants. EPA assumes that sites in transportation equipment
manufacturing, metal product manufacturing, and other product manufacturing sites were likely using
formaldehyde in this manner. The full crosswalk of NAICS to OES used for integration of OSHA
CEHD data is in Appendix D. The other two were provided by Parsons Engineering. The latter study
sampled spray painters while they painted lighting components for aerospace products. The
methodology for obtaining and analyzing this data is described in Section 2.5.1.
Data is not available to estimate ONU exposures; EPA estimates that ONU exposures are lower than
worker exposures because ONUs do not typically directly handle chemicals. In lieu of ONU-specific
data, EPA uses worker central tendency exposure results as a surrogate to estimate exposures for ONUs.
It should be noted that 5 percent of the 8-hour TWA samples measured below the LOD, 44 percent of
the 15-minute samples, 24 percent of 15 minutes to 330 minutes samples, and 44 percent of the samples
measured between 15 and 60 minutes were below the LOD. To estimate exposure concentrations for
these data, EPA followed the Guidelines for Statistical Analysis of Occupational Exposure Data (U.S.
EPA, 1994a), as discussed in Section 2.5.1.
The high-end and central tendency values for the 8-hour TWA data represent the 95th and 50th
percentile, respectively. The calculated values are summarized in Table 3-12.
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Table 3-12. Summary of Inhalation Exposure Monitoring Data for Use of Formulations
Exposure
Concentration
Type
Worker Exposures
Number
of
Worker
Samples
ONU
Exposures
Number of
ONU
Samples
Data Quality
Rating of Air
Concentration
Data
Central
Tendency
(ppm)
High-
End
(ppm)
Full shift
8-hour TWA
0.07
0.48
254
0.07
0
Medium to
High
Short-term
15-minute TWA
0.12
1.08
148
EPA did not identify
short-term data for
ONUs
Medium
>15 to <330 minutes
0.07
0.56
552
Medium
>14 <60 minutes
0.10
1.09
222
Medium
EPA identified one additional study with PBZ monitoring data for the use of formulations containing
formaldehyde for spray applications that did not provide the discrete data to be incorporated into the
inhalation estimates. These data were not included in the estimates listed above but support the exposure
estimates. Thorud (2005) measured full shift exposures to formaldehyde during manual and automatic
spray painting at a facility in Norway. The samples ranged from 0.01 to 1.1 ppm, and the geometric
means ranged from 0.11 to 0.16 ppm, depending on the worker activity.
Lyapina (2004) took full shift measurements of workers whose job tasks involved the application of
carbamide-formaldehyde glue at a site in Bulgaria. The application method is not specified. The samples
ranged from 0.52 to 1.56 ppm and resulted in an arithmetic mean of 0.71 ppm (n = 29).
3.5.1.4 Inhalation Exposure Estimates (Non-spray applications)
EPA did not identify discrete data for specific applications except for spray applications. However, EPA
did identify monitoring data for workers using different application methods (Thorud et al., 2005). The
study collected monitoring data of workers while curtain painting, dip painting, and manual painting at
27 different facilities in the surface coating departments in Norway. The total duration sampled per
worker are not provided but the study indicates two or three samples were measured per worker per
shift. EPA assumes these exposure estimates are representative of a full shift exposure. The study also
indicates that some samples were monitored under an air-purifying mask, thus exposures without the
impact of the respirator may be higher. These specific samples were not specified.
One study conducted in Sweden measured peak (15-minute) exposures of workers during house painting
(Nofback et al. 1995). The study monitored painters during construction of new buildings using water-
based paints using rollers for about 3 to 5 hours per day.
The formaldehyde air concentrations for these non-spray applications and their data quality evaluation
are provided in Table 3-13.
Page 60 of 313
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Table 3-13. Use of Coatings, Paints, Adhesives, or Sealants (Non-spray Applications) Inhalation
Exposure Data
Coating
Application
Number of
Samples
Duration
Geometric
Mean (ppm)
Range
(ppm)
Overall Data
Quality
Determination
Source
Curtain painting
25
Full shift
0.51
0.08-1.48
Medium
(Thorud et
al.. 2005)
Manual painting
16
Full shift
0.07
0.05-0.16
Medium
(Thorud et
al.. 2005)
Dip painting
9
Full shift
0.16
0.10-0.27
Medium
(Thorud et
al.. 2005)
House painters
using rollers with
water-based paints
12
Full shift
0.033
<0.024 to
0.088
Medium
(Norback et
al.. 1995)
House painters
using rollers with
water-based paints
5
Peak
(15-minute)
0.064
<0.024 to
0.112
Medium
(Norback et
al.. 1995)
The monitoring data available by application method indicates that exposures can vary by application
methods with curtain painting being potentially a higher exposure application method. EPA used the
geometric mean exposure estimates for dip painting and curtain painting to inform central tendency and
high-end exposures respectively from non-spray applications from Thorud et al. (2005). For short term
exposures, EPA used the geometric mean and maximum from Norback et al. (1995). The short-term
exposure data identified for these applications may not be representative of peak exposures as indicated
by the 8-hour TWA. To represent peak exposures, EPA uses the higher 8-hour TWA as a surrogate
estimate for peak exposure during non-spray applications.
Table 3-14. Summary of Inhalation Exposure Monitoring Data for Use of Coatings, Paints,
Adhesives, or Sealants (Non-spray Applications)
Exposure
Concentration
Type
Worker Exposures
Number of
Worker
Samples
ONU Exposures
Number of
ONU
Samples
Data Quality
Rating of Air
Concentration
Data
Central
Tendency
High-
end
8-hour TWA
0.16
0.51
50
0.16 0.16
0
Medium
15-minute TWA
0.064
0.112
5
EPA did not identify 15-minute
exposures for workers or ONUs
Medium
Short-term
TWA
EPA did not identify short-term exposures for workers or ONUs
N/A
EPA did not identify discrete data; therefore, the Agency used summary data to estimate a CT (mean of three non-
spray applications) and HE (maximum).
3.5.1.5 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6.
For non-spray applications, EPA assumes that routine dermal exposure may occur. EPA assessed at a
concentration of 60 percent, based on a maximum concentration range of 30 to 60 percent reporting
from solvent-based paints category in the 2020 CDR ( 020a). This relatively high
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concentration is conservatively assessed in cases that sites received concentrated raw materials that they
may dilute or mix prior to application. The calculated occupational dermal exposures for this scenario
are 840 |ig/cm2 as the central tendency value and 1,260 |ig/cm2 as the high-end value.
For spray application, EPA expects a higher quantity remaining on the skin. Based on the expected
worker activities, high-end dermal exposures are calculated based on a higher amount of formaldehyde
remaining on skin (immersive), 10.3 mg/cm2 per event, and the central tendencies of 3.8 mg/cm2 per
event. While the reported range in CDR was 30 to 60 percent, it is not expected for formaldehyde to be
present in final coating products at concentrations of 60 percent. The amount of formaldehyde in
formulation is expected to vary widely as products such as waterborne paints and coatings will have
lower concentrations. A public comment indicated member companies with concentrations below 1%
for commercial adhesives (ASC. 2024). A study of products in a Danish database indicated a maximum
identified concentrations at 17 percent for adhesives and 7.4 percent for paints and varnishes
(Schwensen et at.. 2017). EPA used a concentration of 30 percent based on 2020 CDR to be protective.
The calculated occupational dermal exposures for this OES are 1,140 |ig/cm2 as the central tendency
value and 3,090 |ig/cm2 as the high-end value.
3.6 Processing - Incorporation into an Article - Additive in Rubber
Product Manufacturing
3.6.1 Rubber Product Manufacturing
3.6.1.1 Process Description
Formaldehyde resins are used as an additive in rubber product manufacturing, including products such
as tires (U.S. EPA. 2023a: LISTMA. 2020. 2019; Gunter. 1977; NIPS 3). In tire manufacturing,
formaldehyde based resins are used as crosslinking agents or to build adhesion between different tire
components. Formaldehyde may also be in coatings on fabric belts and tire mold release agents
(TISTMA. 2019). One source indicates a concentration of 8 percent phenol formaldehyde in a rubber-
metal adhesive used for rubber manufacturing (van der Willi gen etai. 1987); however, the amount of
formaldehyde in other components that may be used is unknown.
Many of the rubber manufacturing facilities in the United States produce tires for automotive vehicles,
airplanes, and farm machinery; however, many facilities produce other engineered rubber products (
23a). The processes involved in these industries are similar but may differ in the raw rubber
material and additives used, and the curing method implemented. In general, rubber product
manufacturing involves six main stages: mixing, milling, extrusion, calendaring, curing, and grinding.
The raw rubber (natural or synthetic) is first mixed with chemical additives, including accelerators, zinc
oxides, retarders, antioxidants, softeners, carbon black or other fillers, and sulfur compounds. Mixing
occurs in batch mixers at temperatures up to 330 °F ( >23a).
After mixing, the rubber product is processed into slab rubber or pellets via a drop mill, extruder, or
pelletizer ( 023a). The rubber is cooled and then transferred to the component preparation
area. Calendaring may be used to apply a rubber coat onto a continuous textile or mesh web. The final
step in rubber product manufacturing is vulcanizing, also known as curing. After curing, grinding may
be performed to remove rough edges from the final product ( 023a).
During tire manufacturing, low levels of formaldehyde are present in reinforcing and tackifying resins
(LISTMA. 2020. 2019). The formaldehyde resins are incorporated into the tire compound during mixing,
which may occur at tire manufacturing facilities or separate mixing facilities. Tire compounding is the
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first stage of the tire manufacturing process and involves the selection of several types of rubber, oils,
carbon black, pigments, and other additives (USTMA. 2020. 2019). The tire manufacturing industry
primarily uses natural rubber, styrene-butadiene rubber, and polybutadiene rubber ( 5a).
The raw materials are then mixed using a Banbury mixing machine to form a homogenized batch of
material with a gum-like consistency. The mixing process is computer-controlled. The compounded
materials then undergo further processing into sidewalls, treads, or other parts of the tire. After
processing, the tire is cured by application of pressure (200-300 psig) and heat (330 to 350 °F).
According to a public comment by the U.S. Tire Manufacturers Association, any formaldehyde present
in the resins is expected to be fully consumed during curing (TJSTNI \ J020, JO I • >; U.S. EPA. 1995a).
Formaldehyde is also used during high-pressure hose manufacturing, which is used by the automotive,
oil, and farming industries (Gunter. 1977; NIOS. |). During rubber hose manufacturing, rayon or
polyester cords are treated by a rewinder. The rewinding process involves dipping the cord into a
solution containing formaldehyde. After the cord is treated with formaldehyde, a rubber hose is fed into
a braiding machine. The braiding machine reinforces the rubber hose by braiding the treated cord around
the rubber hose (Gunter. 1977; NIOS, 5)- Due to a lack of information, EPA does not present site
throughputs for rubber hose manufacturing. The concentration of formaldehyde used to treat rayon or
polyester cords is unknown.
3.6.1.2 Worker Activities
Workers are potentially exposed to formaldehyde in rubber product manufacturing during
loading/unloading transport containers, cleaning empty transport containers, coating applications, and
after removing cured products (I. c. < i1 \ J023a; LISTM \ „0 Vs). According to literature sources, PPE
may include safety glasses, gloves, and ear plugs (UST1 '20). Engineering controls may include
point of generation ventilation and overhead exhaust ventilation (USTMA. 2020).
ONUs include employees (e.g., supervisors, managers) at rubber product manufacturing sites who do
not directly handle formaldehyde. Therefore, the ONUs are expected to have lower inhalation exposures,
and no expected dermal exposure.
3.6.1.3 Inhalation Exposure Estimates
The information and data quality valuation to assess occupational exposures during rubber product
manufacturing is listed in Table 3-15 and described in detail below. Table 3-16 summarizes the
monitoring data for the use of formaldehyde in rubber product manufacturing.
Table 3-15. Rubber Product Manufacturing Inhalation Exposure Data Evaluation
Worker Activity or Sampling
Location
Data Type
Number of
Samples
Overall Data Quality
Determination
Source
Press operator during rubber
flooring manufacturing
PBZ monitoring data
1
Medium
(Burkhart.
1995)
Operator during automotive
brake part manufacturing
PBZ monitoring data
6
High
(Mauer and
Cook. 1999)
Mixing, milling, curing, block
cutting, and machine operation
PBZ monitoring data
1,800
High
( "MA.
2020)
Calendaring, raw material
weighing, and receiving areas
Area monitoring data"
12
High
( "MA.
2020)
Mixing, milling, curing, block
cutting, and machine operation
PBZ monitoring data
1,083
High
( "MA.
2024)
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Worker Activity or Sampling
Location
Data Type
Number of
Samples
Overall Data Quality
Determination
Source
Unknown
PBZ monitoring data
113
Medium
("OSHA. 2019)
a 8-hour TWA PBZ data were not available to estimate ONU exposures; therefore, EPA used area samples for the
ONU 8-hour TWA estimates.
A majority of the monitoring data were from the U.S. Tire Manufacturers Association (USTMA)
(TISTMA. 2020). Nine member companies provided monitoring data to USTMA that represent full shift
and 15-minute exposure durations in various worker activities during tire manufacturing. EPA
incorporated sampling data from two NIOSH HHEs investigating exposure to formaldehyde during
rubber flooring manufacturing and automotive brake part manufacturing (Mauer and Cook. 1999;
Burkhart. 1995). Additionally, EPA identified 113 samples from OSHA CEHD in the rubber product
manufacturing subsector. For further discussion of OSHA CEHD data, refer to Section 2.5.1.
Personal breathing zone data were not available to estimate ONU exposures, therefore, EPA used area
samples as surrogate data for the ONU 8-hour TWA estimates. EPA did not identify ONU data for 15-
minute or other short-term estimates. EPA estimates that ONU exposures are lower than worker
exposures since ONUs do not typically directly handle chemicals. In lieu of ONU specific data, EPA
used worker central tendency exposure results as a surrogate to estimate exposures for ONUs.
For the 8-hour TWA data, it should be noted that 26 percent of the worker samples measured below the
LOD. For the 12-hour TWA data, 3 percent of the worker samples measured below the LOD. For the
15-minute and greater than 14-minute to less than 60-minute worker data, 47 and 49 percent of the
samples were below the LOD. For the greater than 15-minute to less than 330-minute data, 12 percent of
the samples were below the LOD. To estimate exposure concentrations for these data, EPA followed the
Guidelines for Statistical Analysis of Occupational Exposure Data ( a), as discussed in
Section 2.5.1.
The high-end and central tendency values for the data represent the 95th and 50th percentile,
respectively. The calculated values are summarized in Table 3-16.
Table 3-16. Summary of Inhalation Exposure Monitoring Data for Rubber Product
Manufacturing
Exposure
Concentration
Type
Worker Exposures
Number
of
Worker
Samples
ONU Exposures"
Number
of ONU
Samples
Data Quality Rating
of Air Concentration
Data
Central
Tendency
(ppm)
High-
End
(ppm)
Central
Tendency
(ppm)
High-
End
(ppm)
8-hour TWA
0.01
0.09
1245
0.018
0.041
12
Medium to High
12-hour TWA
0.02
0.14
1290
EPA did not identify
12-hour TWA for
ONUs
0
High
15-minute
0.02
0.45
125
EPA did not identify
15-minute TWA for
ONUs
0
Medium to High
>15 to <330
minutes
0.005
0.08
330
Medium to High
Page 64 of 313
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Exposure
Concentration
Type
Worker Exposures
Number
of
Worker
Samples
ONU Exposures"
Number
of ONU
Samples
Data Quality Rating
of Air Concentration
Data
Central
Tendency
(ppm)
High-
End
(ppm)
Central
Tendency
(ppm)
High-
End
(ppm)
>14 to <60
minutes
0.035
0.42
136
EPA did not identify
shorter term data for
ONUs
0
Medium to High
" Area samples from (USTMA. 2020). EPA used the area samples for the ONU estimates.
A public comment provided discrete monitoring data at U.S. sites for processing-incorporation into
article (Stantec ChemRisk. 2023). EPA did not integrate the data as no additional process or worker
activity information was provided to attribute to individual occupational exposure scenarios (e.g., type
of produced article). The reported 50th percentile and 95th percentile full shift exposures were 0.08 and
0.313 ppm, respectively. These estimates generally are above the range estimated for this exposure
scenario but it is unclear if this data included rubber product manufacturing.
EPA identified additional studies with PBZ monitoring data for rubber product manufacturing that did
not provide the discrete data to be incorporated into the inhalation estimates. These data were not
included in the exposure estimates listed above. Clerc Q ) compiled monitoring data stored in the
French COLCHIC database and German MEGA database for processes involving the manufacture of
molded rubber parts, injection molding, and activities involving extruders. The databases contained
short-term samples (i.e., between 30 and 240 minutes) with a median of 0.024 ppm, geometric mean of
-0.033 ppm, and a 95th percentile of 0.39 ppm (n = 246). Lee (2012) measured worker exposures at two
tire manufacturing plants in Korea, which ranged from 0.009 to 0.029 ppm. The geometric means of the
data ranged from 0.01 to 0.029 ppm. ECHA (2019) aggregated exposure data for workers in the tyre and
rubber manufacturing industry with a long-term exposure value of 0.26 mg/m3 (0.21 ppm; n = 10). The
data consisted of personal long-term monitoring data.
3.6.1.4 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The assessed concentration for this OES was
0.04 percent based on the 8 percent phenol formaldehyde resin concentration in rubber glue assuming a
free formaldehyde content of 0.5 percent for the phenol-formaldehyde resin (Dm 04; van der
Willieen et at.. 1987). The maximum concentration was used for both high-end and central tendency
calculations. The calculated occupational dermal exposures for this OES are 0.56 |ig/cm2 as the central
tendency value and 0.84 |ig/cm2 as the high-end value.
3.7 Processing - Incorporation into Article - Adhesives and Sealant
Chemicals in Wood Product Manufacturing; Plastic Material and
Resin Manufacturing (Including Structural and Fireworthy Aerospace
Interiors); Construction (Including Roofing Materials); Paper
Manufacturing
EPA evaluated four exposure scenarios for this COU:
• Composite wood product manufacturing,
• Other composite material manufacturing,
• Paper manufacturing, and
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• Plastics product manufacturing.
3,7.1 Composite Wood Product Manufacturing
3.7.1.1 Process Description
Formaldehyde resins are incorporated into adhesives used to manufacture composite wood products
(NICNAS. 2006; Van der Wal. 1982). These products include but are not limited to particleboard,
fiberboard, oriented strand board, and plywood (Solenis. 2020; NICNAS. 2006; Van der W I).
Concentrations of free formaldehyde in the resins used to manufacture these products range from less
than 0.2 to 6 percent (NICNAS. 2006).
The process of incorporating formaldehyde resins into wood products involves injecting the resins with
refined wood fiber, mixing, then rolling and pressing the wood product (NICNAS. 2006; & il..
2001; NZ DOH. 19S I, i-'ioysse. 1980). Types of formaldehyde resins used include urea, phenol,
melamine, or a combination of these resins (NICNAS. 2006). In the case of plywood, the formaldehyde
resins are pumped into glue spreaders and applied to the veneer using rollers, which are then pressed
(NICNAS. 2006; K t I • }80). The manufacture of compressed wood products is an automated
process (Sussell. 1995). Compressed wood products can be used in several construction applications,
such as residential buildings, commercial and industrial structures, furniture, and material handling such
as pallets (NICNAS. 2006; Sussell. 1995).
3.7.1.2 Worker Activities
When manufacturing composite wood products, workers are potentially exposed to formaldehyde during
various processing operations, such as pressing, finishing, milling, blending, sanding, and veneering
(NICNAS. 2006; Lavoue et at.. 2005; Sussell. 1995). Potential exposures are also expected during the
storing/packaging of the composite wood products, as well as during the cleaning of process equipment
and areas (Vangronsveld et at.. 2010). The engineering controls described for composite wood product
manufacturing primarily consisted of different forms of generic ambient ventilation (Sussell. 1995).
ONUs include employees (e.g., supervisors, managers) at composite wood product manufacturing sites
who do not directly handle formaldehyde. Therefore, the ONUs are expected to have lower inhalation
exposures, and no expected dermal exposure.
3.7.1.3 Inhalation Exposure Estimates
The information and data quality valuation to assess occupational exposures during composite wood
product manufacturing is listed in Table 3-17 and described in detail below. Table 3-18 summarizes the
8-hour TWA, short-term, and 15-minute monitoring data for the use of formaldehyde in composite wood
products.
Table 3-17. Composite Wood Product Manufacturing Inhalation Exposure Data Evaluation
Worker Activity or
Sampling Location
Data Type
Number of
Samples
Overall Data
Quality
Determination
Source
Press operator during
fiberboard manufacturing
PBZ monitoring data
3
High
(Sussell, 1995)
Unknown
PBZ monitoring data
555
Medium
(OSHA. 2019)
EPA identified two sources with discrete PBZ monitoring data applicable to this OES. A majority of the
monitoring data is from OSHA CEHD from the wood product manufacturing sector. The other source
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monitored formaldehyde exposures during the manufacturing of fiberboard (Lavoue et ai. 2005;
Fransman et ai. 2003; Sussell. 1995).
EPA did not identify ONU data for 8-hour estimates. The Agency estimates that ONU exposures are
lower than worker exposures because ONUs do not typically directly handle chemicals. In lieu of ONU-
specific data, EPA uses worker central tendency exposure results as a surrogate to estimate 8-hour TWA
exposures for ONUs. For short-term estimates, the Agency identified one ONU sample.
For the 8-hour TWA data, it should be noted that 5.5 percent of the worker samples were below the
LOD. For the short-term worker data, 31 percent of the 15-minute, 17 percent of greater than 15-minute
to less than 330-minute, and 28 percent of greater than 14-minute to less than 60-minute samples were
below the LOD.
The high-end and central tendency values for the data represent the 95th and 50th percentile,
respectively. The calculated values are summarized in Table 3-18.
Table 3-18. Summary of Inhalation Exposure Monitoring Data for Composite Wood Product
Manufacturing
Exposure
Concentration
Type
Worker Exposures
Number
of
Worker
Samples
ONU
Exposures
Number of
ONU
Samples
Data Quality
Rating of Air
Concentration
Data
Central
Tendency
(ppm)
High-
End
(ppm)
Full shift
8-hour TWA
0.09
0.58
161
0.09
N/A
Medium to High
Short-term
15-minute TWA
0.13
1.16
94
EPA did not identify
short-term data for
ONUs
Medium to High
>15 to <330
minutes
0.11
0.83
303
0.08
1
Medium
>14 to <60 minutes
0.15
2.75
123
EPA did not identify
short-term data for
ONUs
Medium to High
A public comment provided discrete monitoring data at U.S. sites for processing-incorporation into
article (Stantec ChemRisk. 2023). EPA did not integrate the data as no additional process or worker
activity information was provided to attribute to individual occupational exposure scenarios (e.g., type
of produced article). The reported 50th percentile and 95th percentile full shift exposures were 0.08 and
0.313 ppm, respectively. These estimates generally fit within the range estimated for this exposure
scenario.
In addition, EPA identified studies that contained personal worker monitoring data but the full
distribution of samples was not available for integration into the inhalation estimates. Five studies
measured at facilities outside of the United States reported worker exposures at plywood mills that use
urea-formaldehyde or phenol-formaldehyde as adhesives (Lin et al.. 2013; NICNAS. 2006; Fran sman et
ai. 2003; Makinen et al.. 1999). Fransman (2003) measured an average (GM) 8-hour worker TWA of
0.057 ppm, which is lower than the central tendency but within a similar range as our exposure
estimates. Between the other four studies, long-term exposures measured at the plywood mills ranged
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from less than 0.01 ppm for feeding of wood scraps to 0.66 ppm for gluing of the veneers (Lin et at..
2013; NICNAS. 2006; Makinen et at.. 1999). In Canada, Lavoue (2005) measured short-term exposures
at 12 plants throughout Quebec that manufactured particleboard, medium density fiberboard, or oriented
strand board. There was a total of 117 samples collected between the facilities, with geometric means
ranging from 0.04 to 0.23 ppm based on job tasks (Lavoue et at.. 2005). EC HA (2019) aggregated
exposure data for workers in the wood panel production industry with an exposure value of 0.075 mg/m3
(n = 81). The data consisted of personal long-term monitoring data.
In 2015, an analysis of the German MEGA and French COLCHIC databases that contain the records of
government-collected worker monitoring data, was completed for formaldehyde. For the facilities within
the industrial sector of manufacture of wood and furniture sector, the central tendency in the French and
German database were 0.10 (n = 466) and 0.06 (n = 1,063) ppm, respectively. For the German database,
the high-end (95th percentile) was 0.57 ppm while the French database's high-end of the dataset was
0.41 ppm (Clerc et at.. 2015).
3.7.1.4 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The maximum concentration identified for this
OES was a reported range of 30 to 60 percent for Processing - incorporation into article - wood product
manufacturing in the 2020 CDR ( 2020a). Other sources indicate the resins, which are the
typical starting material used in wood product manufacturing, contains approximately 0.2 to 6 percent
free formaldehyde (NICNAS. 2006). EPA expects that the range reported in CDR may be the
concentration of formaldehyde in the solutions used to produce the resins, which worker exposures for
these activities are reflected in processing as a reactant. Some facilities may conduct both processes at
their sites. The concentration used for this OES is 6 percent. The calculated occupational dermal
exposures for this OES are 84 |ig/cm2 as the central tendency value and 126 |ig/cm2 as the high-end
value.
3,7.2 Other Composite Material Manufacturing
3.7.2.1 Process Description
Formaldehyde is a constituent in pre-impregnated materials used to manufacture composite materials
such as fibrous insulation, asphalt roofing, and composite panels (ARV \ JO x VN I A. 2019;
NICNAS. 2006). Pre-impregnated materials include reinforcement fibers loaded with a partially cured
resin ( 2024). Fiber glass and mineral wool building insulation products typically contain 3 to 6
percent by weight cured formaldehyde binder ( ). The maximum concentration identified
for this OES was a reported range of 30 to 60 percent for processing -incorporation into article -
construction per the 2020 CDR ( 1020a). Other sources indicate the resins, which are used in
fiberglass composite material manufacturing, contain up to 13 percent of free formaldehyde (NICNAS.
2006).
Formaldehyde resins may be incorporated into binders used in fibrous insulation products (NAIMA.
2019). During fiberglass or mineral wool insulation manufacturing, aqueous solutions of formaldehyde
resin are sprayed onto fibers. The fibers are then sent to a curing oven, in which the binder is thermally
set. According to public comment, virtually all free formaldehyde content is eliminated during the
curing process (NAIMA. 2019).
Urea-formaldehyde resins are incorporated into fiberglass mats used for asphalt roofing (ARMA. 2019).
During the manufacture of fiberglass mats, a binder solution containing formaldehyde resin is uniformly
Page 68 of 313
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applied to the surface of fiberglass mats. A vacuum removes excess binder solution for re-use. The mat
is then passed through drying and curing ovens to remove moisture and set the binder (ARMA. 2019).
Asphalt roofing manufacturing typically involves the following processes: coating, mineral surfacing,
cooling, drying, product finishing, and packaging (AM I \. JO I's; Apol and Oka\\ . s 7).
Finished fiberglass mats may be further incorporated into gypsum wallboard. During gypsum wallboard
production, a gypsum slurry is fed between continuous layers of fiberglass mats to create reinforced
boards. The gypsum slurry recrystallizes as the reinforced boards move down a conveyor belt. The
boards are then cut to length and sent through dryers (Georgia-Pac psum. 2024).
3.7.2.2 Worker Activities
When manufacturing other composite materials, workers are potentially exposed to formaldehyde during
molding operations, resin spraying, and cleaning of mold using a cold blast (Daftarian et at.. 2000).
Workers may also be exposed to formaldehyde during gypsum wallboard production that involve board
cutting and drying (Georgia-Pacific Gypsum. 2024). EPA did not find information that indicates the
extent of engineering controls and use of PPE by workers at facilities that manufacture other composite
materials using formaldehyde-based resins.
ONUs include employees (e.g., supervisors, managers) at other composite materials manufacturing sites
who do not directly handle formaldehyde. Therefore, the ONUs are expected to have lower inhalation
exposures, and no expected dermal exposure.
3.7.2.3 Inhalation Exposure Estimates
The information and data quality valuation to assess occupational exposures during other composite
material manufacturing is listed in Table 3-19 and described in detail below. Table 3-20 summarizes the
monitoring data for other composite material manufacturing. EPA did not identify 12-hour TWA
monitoring data for workers or ONUs.
Table 3-19. Other Composite Material Manufacturing (e.gRoofing) Inhalation Exposure Data
Evaluation
Worker Activity or
Sampling Location
Data Type
Number of
Samples
Overall Data
Quality
Determination
Source
Unknown
PBZ monitoring data
259
Medium
(OSHA. 2019)
The worker samples were from OSHA's CEHD, from the nonmetallic mineral product manufacturing
sector.
For the 8-hour TWA data, it should be noted that 3 percent of the worker samples were below the LOD.
For the short-term worker data, 81 percent of the 15-minute samples, 34 percent of the greater than 15-
minute to less than 330-minute, and 65 percent of greater than 14-minute to less than 60- minute were
below the LOD. The methodology for obtaining and analyzing this data is described in EPA's
Guidelines for Statistical Analysis of Occupational Exposure Data ( a), as discussed in
Section 2.5.1.
Personal breathing zone data for ONUs was not available; therefore, EPA used central tendency of
worker exposure to determine the 8-hour TWA exposure. Short-term and 15-minute data were not
available to estimate ONU exposures.
Page 69 of 313
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The high-end and central tendency values for the data represent the 95th and 50th percentile,
respectively. The calculated values are summarized in Table 3-20.
Table 3-20. Summary of Inhalation Exposure Monitoring Data for Other Composite Material
Manufacturing (e.g., Roofing)
Exposure
Concentration
Type
Worker Exposures
Number of
Worker
Samples
ONU
Exposures
(ppm)
Number
of ONU
Samples
Data Quality
Rating of Air
Concentration
Data
Central
Tendency
(ppm)
High-
End
(ppm)
Full shift
8-hour TWA
0.12
0.38
78
0.12
0
Medium
Short-term
15-minute TWA
0.18
0.37
21
EPA did not identify
15-minute data for
ONUs
Medium
>15 minute to
<330 minute
0.05
0.44
160
EPA did not identify
short-term data for
ONUs
Medium
>14 minute to <60
minute
0.18
0.66
32
EPA did not identify
short-term data for
ONUs
Medium
A public comment provided monitoring summaries for a database maintained by an asphalt roofing
manufacturing industry group. The summaries provided 50th and 95th percentile of the data separated
into roofing plants, and fiberglass mat plants. For full-shift samples measured at fiberglass mat plants,
the 50th percentile was 0.07 ppm and 95th percentile was 0.24 ppm (n = 385). These values skew lower
but are within the range estimated. For roofing plants, formaldehyde concentrations were 0.01 (50th
percentile) and 0.10 (95th percentile) indicating lower formaldehyde concentrations for full-shift
exposures for these processes. For short-term monitoring data, the 50th percentile was 0.22 ppm and the
95th percentile was 0.71 ppm (n = 102) at fiberglass mat plants. These values skew higher than the
short-term estimates for this scenario. The roofing plants, however, have short-term estimates at 0.08 for
50th percentile and 0.38 for 95th percentile, which generally fit within the range estimated for this
exposure scenario (Asphalt Roofing Manufacturers Association. 2024).
Another public comment provided discrete monitoring data at U.S. sites for processing-incorporation
into article (Stantec ChemRisk. 2023). EPA did not integrate the data as no additional process or worker
activity information was provided to attribute to individual occupational exposure scenarios (e.g., type
of produced article). The reported 50th percentile and 95th percentile full shift exposures were 0.08 and
0.313 ppm, respectively. These estimates generally fit within the range estimated for this exposure
scenario.
3.7.2.4 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The maximum concentration identified for this
OES was a reported range of 30 to 60 percent for Processing - incorporation into article - construction
in the 2020 CDR ( 1020a). Other sources indicate the resins, which are used in fiberglass
composite material manufacturing, contain up to 13 percent free formaldehyde (.NUCHAS. 2006). EPA
expects that the range reported in CDR may be the concentration of formaldehyde in the solutions used
to produce the resins, which worker exposures for these activities are reflected in processing as a
Page 70 of 313
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reactant. Some facilities may conduct both processes at their sites. The concentration used for this OES
is 13 percent. The calculated occupational dermal exposures for this OES are 182 |ig/cm2 as the central
tendency value and 273 |ig/cm2 as the high-end value.
3.7.3 Paper Manufacturing
3.7.3.1 Process Description
Formaldehyde resins are incorporated into adhesives and sizing agents used in the manufacturing and
finishing of paper products (Robinson etal. 1986). In the 2020 CDR, one reporter indicated the use of
formaldehyde for paper manufacturing with a 2019 PV of 922,388 lbs ( 320a).
Paper manufacturing often takes place in the same plant which produced pulp (Robinson et at.. 1986).
The pulp product is mixed with water and additives such as sizing agents which can include
formaldehyde compounds. The pulp slurry is then formed into sheets, then dried and coated.
Formaldehyde can also be present in the final coating applied to the paper product ( 1 and Thoburn.
1986). Potential formaldehyde exposures are expected to occur during paper rolling, sizing, dying,
drying, glazing, and coating (Robinson et at.. 1986).
The concentration of formaldehyde in the manufacturing of paper varies. Analyses from the NIOSH
Health Hazard Evaluation from Equitable Bag Co. (Pric )) showed that the formaldehyde
concentration in wet paper stock at the facility were 0.49 to 1.63 mg of formaldehyde per gram of paper.
In the 2020 CDR, the reported concentration of formaldehyde used in paper manufacturing was 30 to 60
percent ( 2020a). Another study on workers at pulp and paper mills CNICNAS. 2006) stated
that the concentration of free formaldehyde in urea and melamine resins used as finishing agents for
paper products was 1.5 percent.
3.7.3.2 Worker Activities
Workers are potentially exposed to formaldehyde in paper manufacturing during paper rolling, sizing,
drying, dying, glazing, and coating (Robinson et at.. 1986). EPA did not find information that indicates
the extent of engineering controls and use of PPE by workers at facilities that perform leather tanning
operations.
ONUs include employees (e.g., supervisors, managers) at paper manufacturing sites who do not directly
handle formaldehyde. Therefore, the ONUs are expected to have lower inhalation exposures, and no
expected dermal exposure.
3.7.3.3 Inhalation Exposure Estimates
The information and data quality valuation to assess occupational exposures during paper manufacturing
is listed in Table 3-21 and described in detail below. Table 3-22 summarizes the monitoring data for the
use of formaldehyde in paper manufacturing.
Table 3-21. Paper Manufacturing Inhalation Exposure Data Evaluation
Worker Activity or
Sampling Location
Data Type
Number of
Samples
Overall Data Quality
Determination
Source
Unknown
PBZ monitoring data
273
Medium
(OSHA. 2019)
All of the monitoring data is from OSHA's CEHD in the paper manufacturing sector. The worker
activities conducted during sampling is unknown. The methodology for obtaining and analyzing this
data is described in Section 2.5.1.
Page 71 of 313
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For the 8-hour TWA data, it should be noted that 27 percent of the worker samples measured below the
LOD. For the short-term worker data, 65 percent of the 15-minute samples, 31 percent of the greater
than 15-minute to less than 330-minute samples, and 57 percent of the greater than 14-minute to less
than 60-minute samples were below the LOD. To estimate exposure concentrations for these data, EPA
followed the Guidelines for Statistical Analysis of Occupational Exposure Data ( 94a). as
discussed in Section 2.5.1.
Data are not available to estimate ONU exposures; EPA estimates that ONU exposures are lower than
worker exposures since ONUs do not typically directly handle chemicals. In lieu of ONU-specific data,
EPA uses worker central tendency 8-hour TWA exposure results as a surrogate to estimate 8-hour TWA
exposures for ONUs.
The high-end and central tendency values for the data represent the 95th and 50th percentile,
respectively. The calculated values are summarized in Table 3-22.
Table 3-22. Summary of Inhalation Exposure Monitoring Data for Paper Manufacturing
Exposure
Concentration
Type
Worker Exposures
Number
of
Worker
Samples
ONU Exposures
Number
of ONU
Samples
Data Quality
Rating of Air
Concentration
Data
Central
Tendency
(ppm)
High-End
(ppm)
Central
Tendency (ppm)
Full shift
8-hour TWA
0.04
0.39
75
0.04
N/A
Medium
Short-term
15-minute
0.12
0.40
31
EPA did not identify short-
term samples for ONUs
Medium
>15 to <330
minutes
0.06
0.43
167
Medium
>14 to <60
minutes
0.11
0.40
56
Medium
A public comment provided discrete monitoring data at U.S. sites for processing-incorporation into
article (Stantec ChemRisk. 2023). EPA did not integrate the data as no additional process or worker
activity information was provided to attribute to individual occupational exposure scenarios (e.g., type
of produced article). The reported 50th percentile and 95th percentile full shift exposures were 0.08 and
0.313 ppm, respectively. These estimates generally fit within the range estimated for this exposure
scenario.
EPA identified an additional study with PBZ monitoring data for paper manufacturing that did not
provide the discrete data to be incorporated into the inhalation estimates. These data were not included
in the exposure estimates listed above. ECHA (2 ) aggregated exposure data for workers in the paper
manufacturing industry with an exposure value of 0.65 mg/m3 (n = 123). The data consisted of personal
long-term monitoring data.
3.7.3.4 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. For the maximum concentration, it was
reported that the resins used in paper treating and coating contained a maximum of 1.5 percent free
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formaldehyde (NICNAS. 2006). The calculated occupational dermal exposures for this OES are 21
|ig/cm2 as the central tendency value and 31.5 |ig/cm2 as the high-end value.
3,7,4 Plastic Product Manufacturing
3.7.4.1 Process Description
According to the 2020 CDR, formaldehyde was reported under incorporation into an article within the
plastic materials and resin manufacturing sector as a binder ( 320a). EPA also identified that
formaldehyde is a raw material in the manufacturing of polyoxymethylene (POM). Formaldehyde
emissions from plastic product manufacturing were additionally identified in polyethylene processes,
possibly from decomposition of the plastic during heating.
In general, for the manufacturing of plastic products, polymer resin is typically received at the
compounding sites from the resin manufacturer in the form of pellets. The plastic resins are then
typically heated and formed into products through extrusion, thermoforming, compression molding,
calendaring, and encapsulation. After the heating and forming processes, the plastic may be further
processed and molded into the finished product. These molding processes can include injection molding,
transfer molding, compression molding, blow molding, and rotational molding. The final plastic product
manufacturing operations are usually finishing and trimming. Solid waste from this process is typically
sent to landfill or incineration ( 04a). A 2003 NIOSH HHE conducted at the Bemis plastic
packaging manufacturing facility stated that the bag manufacturing process consisted of heat sealing and
cutting bags through an automated process which released smoke containing formaldehyde (NIOSH.
2003a).
The concentration of formaldehyde reported in the 2020 CDR for incorporation into an article within the
plastic materials and resin manufacturing sector as a binder was 30 to 60 percent ( )20a).
EPA considers that this concentration may reflect use of formaldehyde to produce the plastic pellets, but
that the free formaldehyde content in the plastic pellets to be much lower.
3.7.4.2 Worker Activities
Workers are potentially exposed to formaldehyde in plastic product manufacturing during if there is off-
gassing of formaldehyde from the pellet and during heating operations ( 004a). Engineering
controls used at plastic product manufacturing sites can include local exhaust ventilation and general
mechanical ventilation (Li. 2017).
ONUs include employees (e.g., supervisors, managers) at plastic product manufacturing sites who do
not directly handle formaldehyde. Therefore, the ONUs are expected to have lower inhalation exposures,
and no expected dermal exposure.
3.7.4.3 Inhalation Exposure Estimates
The information and data quality valuation to assess occupational exposures during plastic product
manufacturing is listed in Table 3-23 and described in detail below. Table 3-24 summarizes the
monitoring data for the use of formaldehyde in plastic product manufacturing.
Page 73 of 313
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Table 3-23. Plastic Product Manufacturing Inhalation Exposure Data Evaluation
Worker Activity or Sampling
Location
Data Type
Number of
Samples
Overall Data
Quality
Determination
Source
Primary and secondary operators
PBZ monitoring data
2
High
(NIOSH. 1998)
Unknown worker activities in
the plastic extrusion department
PBZ monitoring data
3
Medium
(Methner et ah.
2014)
Process techs within the
polyethylene department
PBZ monitoring data
14
Medium
(Burkhart and
Jennison. 1994)
Wicketer and flatbed bagger
operator
PBZ monitoring data
12
High
(Li. 2017)
Maintenance mechanic
PBZ monitoring data
1
High
(Blade. 1996)
Bag machine operator and
floater
PBZ monitoring data
4
High
(NIOSH. 2003a)
Unknown
PBZ monitoring data
364
Medium
(OSHA. 2019)
A majority of the 8-hour TWA monitoring data came from OSHA CEHD in the plastics product
manufacturing and other miscellaneous manufacturing sectors. EPA also incorporated data from NIOSH
HHEs and literature assessing worker exposures at sites associated with the manufacturing of plastic
bags, plastic film, and plastic circuit breaker cases. Some of the 15-minute samples were provided
through a NIOSH HHE that evaluated worker exposure to formaldehyde at a plastic bag sealing plant
(Li. 2017). One of the short-term data points is from a maintenance mechanic at a facility that
manufactures polyethylene plastic films and bags (Blade. 1996).
EPA did not identify ONU data for exposure estimates. EPA estimates that ONU exposures are lower
than worker exposures since ONUs do not typically directly handle chemicals. In lieu of ONU-specific
data, EPA uses worker central tendency exposure results as a surrogate to estimate 8-hour TWA
exposures for ONUs.
For the 8-hour TWA data, it should be noted that 11 percent of the samples measured below the LOD.
For the 15-minute worker data, 61 percent of the samples were below the LOD and 55 percent for
samples measured for 15 minute up to 60-minutes. For data between 15 minute and 330-minute, 21
percent of the samples were below the LOD. To estimate exposure concentrations for these data, EPA
followed the Guidelines for Statistical Analysis of Occupational Exposure Data ( 94a). as
discussed in Section 2.5.1.
The high-end and central tendency values for the data represent the 95th and 50th percentile,
respectively. The calculated values are summarized in Table 3-24.
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Table 3-24. Summary of Inhalation Exposure Monitoring Data for Plastic Product Manufacturing
Exposure
Concentration
Type
Worker Exposures
Number
of Worker
Samples
ONU
Exposures
Number of
ONU
Samples
Data Quality Rating of
Air Concentration
Data
Central
Tendency
(ppm)
High-
End
(ppm)
Central
Tendency
(ppm)
Full shift
8-hour TWA
Exposure
Concentration
0.06
0.36
184
0.06
0
Medium to High
Short-
term
15-minute
0.07
0.51
181
No short-term ONU
data was available
Medium to High
>15 to <330
minutes
0.12
0.56
387
Medium to High
>14 to <60
minutes
0.09
0.62
262
Medium to High
A public comment provided discrete monitoring data at U.S. sites for processing-incorporation into
article (Stantec ChemRisk. 2023). EPA did not integrate the data as no additional process or worker
activity information was provided to attribute to individual occupational exposure scenarios (e.g., type
of produced article). The reported 50th percentile and 95th percentile full shift exposures were 0.08 and
0.313 ppm, respectively. These estimates generally fit within the range estimated for this exposure
scenario.
EPA identified additional studies with PBZ monitoring data for plastic product manufacturing that did
not provide the discrete data to be incorporated into the inhalation estimates. These additional studies
suggest that exposures to formaldehyde may be more variable, likely dependent on temperature and type
of plastic pellet. In a 2002 NIOSH HHE conducted at Rubbermaid, Inc., arithmetic means of the
monitoring data ranged from 0.52 to 1.75 ppm for full shift press operators (Barsan. 1994). Monitoring
data from two Canadian sites involved in polyethylene extrusion ranged from 0.01 to 0.2 ppm for full
shift worker activities including extrusion coating, blown film, rotational film, blow molding, and pipe
extrusion (Tikuisis et at.. 2010; Tikuisis et at.. 1995).
Bono et al. (.^ I ) and Romanazzi et al. (JO I <) measured worker exposures at a plastics laminate plants
in Italy. The arithmetic mean for the plant workers and ONUs were 0.17 and 0.03 ppm, respectively.
Four studies measured at facilities in Italy reported worker exposures that use formaldehyde in plastic
product manufacturing (Scarselli et al.. 2017; Bono et al.. 2016; Romanazzi et al.. 2013). For workers,
the arithmetic means ranged from 0.065 to 0.17 ppm, and for ONUs, the arithmetic mean was 0.03 ppm.
Hoseood et al. ( and Rothman et al. (2017) measured worker exposures in China at a facility that
uses formaldehyde-melamine resins to product plastic utensils. The data ranged from 0.51 to 2.6 ppm,
and the arithmetic mean was 1.28 ppm.
3.8 Processing - Incorporation into a Formulation, Mixture, or Reaction
Products - [All Functions] in [All Industries]
COUsi
• Petrochemical manufacturing, petroleum, lubricating oil and grease manufacturing; fuel and fuel
additives; lubricant and lubricant additives; all other basic organic chemical manufacturing; all
other petroleum and coal products manufacturing;
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• Asphalt, paving, roofing, and coating materials manufacturing;
• Solvents (which become part of a product formulation or mixture) in paint and coating
manufacturing;
• Processing aids, specific to petroleum production in: oil and gas drilling, extraction, and support
activities; all other chemical product and preparation manufacturing; and all other basic
inorganic chemical manufacturing;
• Paint additives and coating additives not described by other categories in: paint and coating
manufacturing; plastic material and resin manufacturing;
• Intermediate in: all other basic chemical manufacturing; all other chemical product and
preparation manufacturing; plastic material and resin manufacturing; oil and gas drilling,
extraction, and support activities; wholesale and retail trade;
• Other: preservative in all other chemical product and preparation manufacturing;
• Solid separation agents in miscellaneous manufacturing;
• Agricultural chemicals (nonpesticidal) in: agriculture, forestry, fishing, and hunting; pesticide,
fertilizer, and other agricultural chemical manufacturing;
• Surface active agents in plastic material and resin manufacturing;
• Ion exchange agents in adhesive manufacturing and paint and coating manufacturing;
• Lubricant and lubricant additive in adhesive manufacturing;
• Plating agents and surface treating agents in all other chemical product and preparation
manufacturing;
• Soap, cleaning compound, and toilet preparation manufacturing;
• Other: laboratory chemicals;
• Adhesive and sealant chemical in adhesive manufacturing; and
• Bleaching agents in textile, apparel, and leather manufacturing.
3.8.1 Processing of Formaldehyde into Formulations, Mixtures, or Reaction Products
3.8.1.1 Process Description
Incorporation into a formulation, mixture, or reaction product refers to the process of mixing or blending
several raw materials to obtain a product or mixture. Formaldehyde can be incorporated into solvents
which become part of a product formulation or mixture, processing aids, paint and coating additives,
intermediates in basic chemical manufacturing, preservatives in chemical product and preparation
manufacturing, solid separation agents, surface active agents, adhesives, functional fluids, laboratory
chemicals, bleaching agents, and finishing agents (U.S. EPA. 2023b. 2020a. b; AC A. 2019: Bruno et at..
2018: Wicks and Jones. 2013: NICNAS. 2006: Kullman. 1989: Almaguer and Boiar 5; Rivera.
)
In the 2020 CDR, 41 reporters reported the use of formaldehyde for incorporation into formulations
( 2020a). The CDR indicates that formaldehyde is incorporated into formulations in the
following manufacturing industrial sectors: all other basic organic chemicals; all other chemical
products and preparation; paint and coating; pesticide, fertilizer, and other agricultural chemicals;
plastics material and resin; soap, cleaning compound, and toilet preparation; textiles, apparel, and
leather; transportation equipment; and wood product manufacturing. Additionally, formaldehyde is
incorporated into formulations in agriculture, forestry, hunting, and fishing; mining (except oil and gas)
and support activities; oil and gas drilling, extraction, and support activities; wholesale and retail trade;
other (laboratory chemical); and services (embalming agent) ( 2020a). Within these industrial
sectors, formaldehyde is incorporated into binders, laboratory chemicals, preservatives, dispersing
agents, sealants, monomers, chelating agents, surfactants, processing aids specific to petroleum
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production, embalming agents, deodorizers, adhesion/cohesion promoters, soil amendments (fertilizer),
and intermediates (U.S. EPA. 2020a)
Public comments have indicated the use of formaldehyde in the production of ion-exchange resins,
phenolic fillers, coatings, pesticides, lubricants, and polymers, as well as electroless copper plating
processes and petrochemical manufacturing (Celanese Corp. 2020; SIA. 2020; \ i \ JO I's; ARM A.
2019; IPC International. 2019; Material Research. 2019). Urea-formaldehyde concentrates are used for
oilfields, refineries, and petrochemical applications (Material Research. 2019). The refinery industry
employs a variety of processes and typically involves separation, petroleum conversion, petroleum
treating, feedstock and product handling, and auxiliary facilities ( lb).
EPA did not find specific container information for formaldehyde used in the formulation; however, the
Agency expects formaldehyde to arrive as a liquid in tank trucks, drums, or rail cars received directly
from manufacturing sites.
Incorporation of formaldehyde into formulations is generally a batch process (NICNAS. 2006).
Measured amounts of formaldehyde or products containing formaldehyde are added to mixing vessels to
form end products. Formalin or other formaldehyde products containing 0.7 to 37 percent formaldehyde
is typically used. The product is then pumped or manually transferred to containers and shipped to
customers. Blending processes may vary from site to site. Small batch productions typically employ
manual processes, including decanting, weighing, stirring, and cleaning. Large batch productions use
automated processes such as mechanical stirring. Formulation batch times may take anywhere from 5
minutes to 3 days (NICNAS. 2006).
Several OECD ESDs provide general process descriptions for formulation of products. For example,
adhesives are typically formulated by mixing volatile and non-volatile chemical components in sealed,
unsealed, or heated processes (QE )09a). Sealed processes are generally the most common for
adhesive formulation because many adhesives are designed to set or react when exposed to ambient
conditions (l )9a). Paint and coating formulation may involve processes such as dispersion,
milling, mixing, and filtration (OECD. 2009b). Lubricant formulation generally comprises blending two
or more components, including liquid and solid additives, together in a blending vessel (QE »04b).
3.8.1.2 Worker Activities
Workers are potentially exposed to formaldehyde in processing of formaldehyde into formulations,
mixtures, or reaction products during filtering and packaging activities, cleaning and maintenance of
process equipment, and other process activities such as mixing, filling, and blending (NICNAS. 2006).
Engineering controls for these processes can include general and local exhaust ventilation (NICNAS.
2006).
ONUs include employees (e.g., supervisors, managers) at sites which process formaldehyde into
formulations, mixtures, or reaction products who do not directly handle formaldehyde. Therefore, the
ONUs are expected to have lower inhalation exposures, and no expected dermal exposure.
3.8.1.3 Inhalation Exposure Estimates
The information and data quality valuation to assess occupational exposures during processing of
formaldehyde into formulations, mixtures, or reaction products is listed in Table 3-25 and described in
detail below. Table 3-26 summarizes the monitoring data for the processing of formaldehyde into
formulations, mixtures, or reaction products.
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Table 3-25. Processing of Formaldehyde into Formulations, Mixtures, or Reaction Products
Inhalation Exposure Data Eva
uation
Worker Activity or Sampling
Location
Data Type
Number of
Samples
Overall Data
Quality
Determination
Source
Various worker activities such as
field process operator, operator,
and assistant operator
PBZ monitoring data
9
High
( \«i H \ in s Corporation,
20 1 ,'u)
Loading/unloading trucks,
making formulation batches
PBZ monitoring data
2
Medium
(Baviess Kilgore. 2020)
Environmental health and safety,
quality control/quality assurance,
logistics, maintenance, and
operators
PBZ monitoring data
56
High
("Stantec ChemRisk.
2023)
Unknown
PBZ monitoring data
149
Medium
(OSHA. 2019)
For the 8-hour TWA data, 56 of the worker samples were from ACC (Stantec ChemRisk. 2023). This
data was collected by the ACC from major formaldehyde processing facilities in the U.S. Due to the
wide range of facilities that provided data to ACC, it should be noted that this data may overlap with the
other sources identified through the systematic review process. Additionally, EPA incorporated
sampling data from OSHA CEHD in the chemical manufacturing sector. For the specific NAICS codes,
refer to Appendix D.
EPA did not identify ONU data for exposure estimates. EPA estimates that ONU exposures are lower
than worker exposures since ONUs do not typically directly handle chemicals. In lieu of ONU-specific
data, EPA uses worker central tendency exposure results as a surrogate to estimate 8-hour TWA
exposures for ONUs.
It should be noted that 20 percent of the 8-hour TWA samples measured below the LOD, 47 percent of
the 15-minute samples, 29 percent of 15 minutes to 330 minutes samples, and 45 percent of the samples
measured between 15 and 60 minutes were below the LOD. To estimate exposure concentrations for
these data, EPA followed the Guidelines for Statistical Analysis of Occupational Exposure Data (U.S.
), as discussed in Section 2.5.1.
The high-end and central tendency values for the data represent the 95th and 50th percentile,
respectively. The calculated values are summarized in Table 3-26.
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Table 3-26. Summary of Inhalation Exposure Monitoring Data for Processing of Formaldehyde
into Formulations, Mixtures, or Reaction Products
Exposure
Concentration
Type
Worker Exposures
Number
of
Worker
Samples
ONU Exposures
Number
of ONU
Samples
Data Quality
Rating of Air
Concentration
Data
Central
Tendency
(ppm)
High-
End
(ppm)
Central
Tendency (ppm)
Full shift
8-hour TWA
0.07
0.53
127
0.07
0
Medium to High
Short-
term
15-minute
0.15
2.91
86
No short-term ONU data was
available
Medium to High
>15 to <330
minutes
0.08
1.12
176
Medium to High
>14 to <60
minutes
0.13
2.49
114
Medium to High
EPA identified additional studies with PBZ monitoring data for the processing of formaldehyde into
formulations, mixtures, or reaction products that did not provide the discrete data to be incorporated into
the inhalation estimates. These data were not included in the exposure estimates listed above. Dow
Chemical (2016) measured full shift worker exposures on the production line, ranging from 0.064 to
0.16 ppm. In the 2006 formaldehyde NICNAS report, monitoring data from an Australian film
processing formulation site ranged from 0.1 to 2.0 ppm for full shift exposures and 0.3 to 2.0 ppm for
15-minute exposures (NICNAS. 2006). The full shift workers were involved in line setting, packaging,
mixing, and filling, and the 15-minute worker activities involved cleaning and maintenance. ECHA
Q ) aggregated exposure data for workers in the formulation industry with an exposure value of 0.11
mg/m3 (n = 13). The data consisted of personal long-term monitoring data.
3.8.1.4 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The maximum concentration assessed for this
OES was 60 percent based on reporting from the Processing of formaldehyde into formulations OES in
the 2020 CDR (U.S. EPA. 2020a). The minimum concentration reported for this OES was 0.7 percent
based on data from the 2006 formaldehyde report from the NICNAS (NICNAS. 2006). The calculated
occupational dermal exposures for this OES are 840 |ig/cm2 as the central tendency value and 1,260
|ig/cm2 as the high-end value.
3.9 Processing-Repackaging- Sales to distributors for laboratory chemicals
EPA evaluated one exposure scenario for this COU:
• See Section 3.2.1, Import and/or Repackaging of Formaldehyde
3.10 Processing-Recycling
3.10.1 Recycling
COU: Processing - recycling
3.10.1.1 Process Description
Recycling of Medium-Density Fiberboard
The concentration of urea-formaldehyde (UF) in medium-density fiberboard (MDF) panels ranges from
8 to 12 percent (Wan et al., 2014). According to another study, the concentration of free formaldehyde
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in oriented strandboard containing phenol-urea-formaldehyde resin is 5 percent (Oh and Kim, 2015).
During the recycling process for MDF panels, there exists a potential for the emission of formaldehyde
(Moezzipour et al., 2018).
The most common resins used in the production of MDF boards are urea-formaldehyde and melamine
urea-formaldehyde. The goal of recycling these boards is to release the fibers from the resin matrix by
breaking resin bindings. One of the methods for recycling MDF is hydrothermal (Moezzipour et al.,
2018). When recycling MDF wastes by hydrothermal methods, first fibers are heated using steam
(hydrothermal), and then they are separated using a refiner (Moezzipour et al., 2018). Fibers degenerate
upon continuous heating at high temperatures and mechanical defibrillation (Moezzipour et al., 2018).
Another common method for recycling MDF panels is through the process of electrical heating. The
resin bindings in the panels are opened through the application of heat from an electrical source, and the
fibers are then separated with a similar process to the hydrothermal separation (Moezzipour et al., 2018).
Recycling of Electronic Waste
Formaldehyde may be present during the process of recycling electronic waste (e-waste) as the polymer
phenol formaldehyde (PF) is used in electronic applications (Flaris et al.. 2009). The recycling process
of e-waste typically begins with the recovery of waste from different storage facilities (Flaris et al..
2009). The waste then usually undergoes a pretreatment technology consisting of washing, size
reduction, sorting, and melt filtration (Flaris et al.. 2009). The sorting of plastics is the typical next step
in the process and may use separation techniques such may include density-based sorting, electrostatic
sorting, and others (Flaris et al.. 2009). The formal recycling process can consist of either a mechanical,
chemical or thermal recycling process (Flaris et al.. 2009).
3.10.1.2 Worker Activities
For recycling activities, workers are potentially exposed to formaldehyde during loading and unloading
of transport containers, and during pretreatment processes such as washing and sorting. Workers may
also be exposed via inhalation or dermal pathways during container and equipment cleaning. EPA did
not find information that indicates the extent of engineering controls and use of PPE by workers at
facilities that recycle formaldehyde.
ONUs include employees (e.g., supervisors, managers) at the recycling site who do not directly handle
formaldehyde. Therefore, the ONUs are expected to have lower inhalation exposures, and no expected
dermal exposure.
3.10.1.3 Inhalation Exposure Estimates
As shown in Table 3-27, EPA identified personal sampling data from OSHA CEHD for recyclable
material merchant wholesalers. With review of company websites, EPA expects that the sites may
involve recycling processes.
Table 3-27. Recycling Data Evaluation
Worker Activity or Sampling
Location
Data Type
Number of
Samples
Overall Data
Quality
Determination
Source
Unknown
PBZ monitoring data
27
Medium
(OSHA. 2019)
EPA did not identify ONU data for exposure estimates. EPA estimates that ONU exposures are lower
than worker exposures since ONUs do not typically directly handle chemicals. In lieu of ONU-specific
Page 80 of 313
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data, EPA uses worker central tendency exposure results as a surrogate to estimate 8-hour TWA
exposures for ONUs.
For the 15-minute to 330 minute data, it should be noted that 17 percent of the samples measured below
the LOD. To estimate exposure concentrations for these data, EPA followed the Guidelines for
Statistical Analysis of Occupational Exposure Data (U. 4a), as discussed in Section 2.5.1.
The high-end and central tendency values for the data represent the 95th and 50th percentile,
respectively. The calculated values are summarized in Table 3-26.
Table 3-28
. Summary of Inhalation Monitoring Data for Recycling
Exposure
Concentration
Type
Worker Exposures
Number
of
Worker
Samples
ONU Exposures
Number
of ONU
Samples
Data Quality
Rating of Air
Concentration
Data
Central
Tendency
(ppm)
High-
End
(ppm)
Central
Tendency (ppm)
Full shift
8-hour TWA
0.22
0.44
7
0.22
0
Medium to High
Short-
term
15-minute
No data identified
No short-term ONU data was
available
Medium to High
>15 to <330
minutes
0.09
0.59
20
Medium to High
>14 to <60
minutes
No data identified
Medium to High
The products containing formaldehyde that are typically recycled include paper, plastic products, and
composite wood products. These processes usually include a breakdown step but the process generally
includes similar process as manufacturing the raw material. EPA expects that recycling process can be
similar to the original manufacturing of these products. Therefore, inhalation exposures during original
manufacturing such as paper or wood product manufacturing may also be analogous to exposures
experienced by workers during recycling.
3.10.1.4 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The maximum concentration assessed for this
OES was 5 percent based on a study of the phenol-urea-formaldehyde resin concentration in oriented
strandboard (Oh and Kim, 2015). The calculated occupational dermal exposures for this OES are 70
|ig/cm2 as the central tendency value and 105 |ig/cm2 as the high-end value.
3.11 Distribution in Commerce
3.11.1 Storage and Retail Stores
COU: Distribution in commerce
3.11.1.1 Process Description
Distribution into commerce includes any distributive activity (e.g., transportation) in which benefit is
gained by the transfer, even if there is no direct monetary gain. TSCA section 3(5) states that the terms
"distribute in commerce" and "distribution in commerce" when used to describe an action taken with
respect to a chemical substance or mixture or article containing a substance or mixture mean to sell, or
the sale of, the substance, mixture, or article in commerce; to introduce or deliver for introduction into
Page 81 of 313
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commerce, or the introduction or delivery for introduction into commerce of, the substance, mixture, or
article; or to hold, or the holding of, the substance, mixture, or article after its introduction into
commerce. EPA anticipates that formaldehyde and its products are distributed throughout commerce for
the COUs evaluated throughout other lifecycle stages assessed in this evaluation. The physical form of
formaldehyde in transit can vary amongst the different COUs in this assessment. Domestically
manufactured commodity chemicals, such as formaldehyde, may be shipped within the United States in
liquid cargo barges, railcars, tank trucks, tank containers, intermediate bulk containers (IBCs)/totes, and
drums. Both imported and domestically manufactured commodity chemicals may be repackaged by
wholesalers for resale, such as repackaging bulk packaging into drums or bottles (Tomer and Kane,
2015) which is assessed in Section 3.2.1.
Distribution in commerce may include loading and unloading activities that occur during other life cycle
stages (e.g., manufacturing, processing, use, disposal), transit activities that involve the movement of
formaldehyde (e.g., via motor vehicles, railcars, water vessels), and temporary storage and warehousing
of the chemical during distribution (excluding repackaging and other processing activities, which are
included in other COUs). EPA assesses loading and unloading throughout the various life cycle stages
and COUs rather than a single distribution scenario. Data for assessing occupational exposures occurring
during the transportation of chemicals between facilities, such as those from accidental spills, are
generally not reasonably available. EPA considers that mixtures or formulations containing
formaldehyde would be in sealed containers; however, articles may not be stored in sealed containers.
As formaldehyde exposure from articles has been reported, The Agency assessed exposure estimates
based on sites expected to store articles containing formaldehyde (e.g., wood products, textiles, plastics).
3.11.1.2 Worker Activities
Workers are potentially exposed to formaldehyde during distribution in commerce of formaldehyde and
formaldehyde products, primarily during loading and unloading activities, and transit activities (U.S.
20b). EPA did not find information that indicates the extent of engineering controls and PPE
used by workers at facilities that perform distribution in commerce operations.
ONUs include employees (e.g., supervisors, managers) at distribution in commerce sites who do not
directly handle formaldehyde. Therefore, the ONUs are expected to have lower inhalation exposures,
lower vapor-through-skin uptake, and no expected dermal exposure.
3.11.1.3 Inhalation Exposure Results
The information and data quality valuation to assess occupational exposures during storage and retail is
listed in Table 3-29 and described in detail below. Table 3-30 summarizes the 8-hour TWA, monitoring
data for the use of formaldehyde in storage and retail.
Table 3-29. Storage and Retail Stores Inhalation Exposure Data Evaluation
Worker Activity or
Sampling Location
Data Type
Number of Samples
Overall Data Quality
Determination
Source
Unknown
PBZ monitoring data
113
Medium
( 3A.2019)
All of the monitoring data is from OSHA's CEHD in the merchant wholesalers, durable and nondurable
goods sectors. The worker activities conducted during sampling is unknown. The methodology for
obtaining and analyzing this data is described in Section 2.5.1.
It should be noted that 39 percent of the 8-hour TWA samples measured below the LOD, 25 percent of
the 15-minute samples, 49 percent of 15 minutes to 330 minutes samples, and 27 percent of the samples
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measured between 15 and 60 minutes were below the LOD. To estimate exposure concentrations for
these data, EPA followed the Guidelines for Statistical Analysis of Occupational Exposure Data (U.S.
), as discussed in Section 2.5.1.
EPA did not identify ONU data for exposure estimates. The Agency estimates that ONU exposures are
lower than worker exposures since ONUs do not typically directly handle chemicals. In lieu of ONU-
specific data, EPA uses worker central tendency exposure results as a surrogate to estimate 8-hour TWA
exposures for ONUs.
The high-end and central tendency values for the data represent the 95th and 50th percentile,
respectively. The calculated values are summarized in Table 3-30.
Table 3-30. Summary of Inhalation Exposure Monitoring Data for Storage and Retail
Exposure
Concentration Type
Worker Exposures
Number of
Worker
Samples
ONU
Exposures
Number of
ONU
Samples
Data Quality Rating
of Air
Concentration Data
Central
Tendency
(ppm)
High-End
(ppm)
8-hour TWA
0.11
0.47
39
0.11
0
Medium
15-minute
0.09
0.45
25
EPA did not identify
15-minute data for
ONUs
>15 to <330 minutes
0.07
0.51
49
>14 to <60 minutes
0.09
0.45
27
3.12 Industrial Use - Non-incorporative Activities - Used in: Construction
3,12,1 Furniture Manufacturing
COU: Industrial use - non-incorporative activities - used in: construction
3.12.1.1 Process Description
Furniture manufacturing includes several sources of formaldehyde exposures including use of composite
wood products, coatings and adhesives containing formaldehyde, textile products, and others. Liquid
spray coatings are used in the metal and wooden furniture industry (U.S. EPA. 2004b). Coatings may be
used directly from the manufacturer, or they may be mixed with a solvent or other components to
achieve the desired viscosity. If coatings are used directly as received from the manufacturer, they are
typically stirred to ensure that all components in the coating are uniformly distributed. Coatings may be
continuously mixed in tanks that are sized appropriately for the expected usage of the coating.
Metal furniture requires surface cleaning before coating application. Cleaning typically involves alkaline
or acidic cleaning, water rinse, phosphate treatment, another water rinse, pretreatment (application of
rust inhibitor or adhesion promotor), and/or water rinse, and finally drying. Coatings are applied either
manually or automatically in spray booths that contain dry filters to collect overspray. Overspray may be
disposed of as waste or reused. After the application of a coating, metal furniture is transferred to a
flash-off area and then to a curing oven, whereas wooden furniture is cured between each coating
application. The wooden furniture may be sent through coating and curing multiple times before the
final wooden part is produced. Interior wooden furniture may require additional finishing steps such as
staining, wash coating, filling, and sealing. Exterior wooden furniture finishing involves similar steps as
interior wooden furniture, except exterior furniture is typically primed with fungicide and water-
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repellant. After the wooden furniture has been stained or painted, a topcoat such as a varnish or shellac
may be applied (U.S. EPA. 2004b).
3.12.1.2 Worker Activities
Workers are potentially exposed to formaldehyde during furniture manufacturing, primarily during
cutting and machining of the panel boards and coating application processes. Workers may also be
exposed via inhalation and dermal pathways during loading/unloading of transport containers
lamination, and container and equipment cleaning (Peteffi et at.. 2015). EPA did not find information
that indicates the extent of engineering controls and PPE used by workers at facilities that perform
furniture manufacturing in the United States.
ONUs include employees (e.g., supervisors, managers) at furniture manufacturing sites who do not
directly handle formaldehyde. Therefore, the ONUs are expected to have lower inhalation exposures,
lower vapor-through-skin uptake, and no expected dermal exposure.
3.12.1.3 Inhalation Exposure Estimates
The information and data quality valuation to assess occupational exposures during furniture
manufacturing is listed in Table 3-31 and described in detail below. Table 3-32 summarizes the
monitoring data for furniture manufacturing.
Table 3-31. Furniture Manufacturing Inhalation Exposure Data Evaluation
Worker Activity or
Sampling Location
Data Type
Number of
Samples
Overall Data Quality
Determination
Source
Sewer and cushion finisher
to make cushions for
outdoor furniture
PBZ monitoring data
6
High
(Marlow, 1995)
Unknown
PBZ monitoring data
640
Medium
(OSHA. 2019)
EPA recognizes that worker job titles and activities may vary significantly from site to site; therefore,
the Agency typically identified samples as worker samples unless it was explicitly clear from the job
title (e.g., inspectors) and the description of activities in the report that the employee was not directly
involved in furniture manufacturing during the sampling period.
Of the 162 8-hour TWA PBZ samples available, 156 were from OSHA's CEHD in the furniture and
related product manufacturing sector. The methodology for obtaining and analyzing this data is
described in Section 2.5.1. The other source sampled cushion manufacturing in the United States in 1995
(Peteffi et al.. 2015; Mario 5). The shorter term samples were all OSHA CEHD from furniture and
related product manufacturing sector.
Data is not available to estimate ONU exposures; EPA estimates that ONU exposures are lower than
worker exposures since ONUs do not typically directly handle chemicals. In lieu of ONU-specific data,
EPA uses worker central tendency exposure results as a surrogate to estimate exposures for ONUs.
It should be noted that 9 percent of the 8-hour TWA samples measured below the LOD, 53 percent of
the 15-minute samples, 9 percent of 15 minutes to 330 minutes samples, and 46 percent of the samples
measured between 15 and 60 minutes were below the LOD. To estimate exposure concentrations for
these data, EPA followed the Guidelines for Statistical Analysis of Occupational Exposure Data (U.S.
), as discussed in Section 2.5.1
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The high-end and central tendency values for the data represent the 95th and 50th percentile,
respectively. The calculated values are summarized in Table 3-32.
Table 3-32. Summary of In
lalation Exposure Monitoring I
>ata for Furniture Manufacturing
Exposure
Concentration
Type
Worker Exposures
Number
of Worker
Samples
ONU
Exposures
Number
of ONU
Samples
Data Quality
Rating of Air
Concentration
Data
Central
Tendency
(ppm)
High-
End
(ppm)
Full shift
8-hour TWA
0.01
0.78
165
0.01
N/A
Medium to High
Short-term
15-minute
0.11
1.0
111
EPA did not identify
short-term data for
ONUs
Medium
>15 to <330
minutes
0.11
0.84
364
Medium
>14 to <60
minutes
0.11
0.96
145
Medium
EPA identified additional studies with PBZ monitoring data for furniture manufacturing that did not
provide the discrete data to be incorporated into the inhalation estimates. These data were not included
in the exposure estimates listed above. A public commenter provided average formaldehyde
concentrations in the board warehouse, during lamination, and other various manufacturing activities at
some furniture manufacturers. The average concentrations ranged from 0.017 (short-term) for
miscellaneous activities to the highest during lamination (8-hour TWA), 0.12 ppm. While some of the
activities measured are below the central tendency estimates, the average of the highest activity of
lamination is similar to the central tendency estimates (Ahfa. 2024).
Vinzents (1993) measured full shift worker exposures during furniture painting and gluing in a Denmark
furniture manufacturing site. The geometric mean of the data collected during painting was 0.16 ppm (n
= 43), and during gluing was 0.91 ppm (n = 396). Thetkathuek (2016) conducted monitoring data at a
medium-density fiberboard manufacturing site in Thailand. The full shift worker exposures ranged from
0.0 to 21 ppm, with arithmetic means ranging from 0.57 to 8.3 ppm. The worker activities included
drilling, edging, laminating, and packing. The study also measured ONU exposures ranging from 0.0 to
4.2 ppm, with an arithmetic mean of 1.52 ppm (n = 12). Ioras ( ) collected short-term monitoring
data for workers conducting spray coating at furniture manufacturing sites in Malaysia, Indonesia,
Thailand, and Vietnam. The samples ranged from 1.7 to 2.2 ppm, with an arithmetic mean of 1.9 ppm (n
= 2000). ECHA (2019) aggregated exposure data for workers in the furniture industry with an exposure
value of 0.88 mg/m3 (n = 36). The data consisted of personal and stationary long- and short-term
monitoring data.
3.12.1.4 Dermal Exposure Results
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The maximum concentration assessed for this
OES was 30 percent, based on CDR data on adhesives and varnishes that may be used in furniture
manufacturing. The calculated occupational dermal exposures for this OES are 420 |ig/cm2 as the central
tendency value and 630 |ig/cm2 as the high-end value.
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3.13 Industrial Use - Non-incorporative Activities - Oxidizing/Reducing
Agent, Processing Aids, Not Otherwise Listed
3,13,1 Processing Aid
3.13.1.1 Process Description
Formaldehyde is used as a reducing agent in the electroless copper plating process to reduce Cu2+ ions to
Cu° (IPC International. 2019). The electroless copper plating process includes hole formation, hole wall
prep, electroless copper hole wall plating, and electrolytic hole wall plating. The formaldehyde
concentration for electroless copper plating processes ranges from 3 to 6 g/L (IPC International. 2019).
Formaldehyde is used in the semiconductor manufacturing industry as a processing aid for metal plating
formulations (SIA. 2020). Formaldehyde may be present in semiconductor products as a byproduct in
concentrations less than 10 ppm. Semiconductor device fabrication creates integrated circuits present in
electronic devices. The fabrication process starts with a semiconductor material wafer. During the
photolithography step, the wafer is coated with photoresist material and covered with a mask that
defines patterns to be retained or removed in the following processing steps. Formaldehyde may be
present in the photoresist material utilized in this step of the process (I s20).
3.13.1.2 Worker Activities
Workers are potentially exposed to formaldehyde during the use of formaldehyde as a processing aid
during the application of photolithographic materials and the manufacturing of semiconductors (SIA.
2020). EPA did not find information that indicates the extent of engineering controls and PPE used by
the workers at facilities that perform semiconductor manufacturing operations.
ONUs include employees (e.g., supervisors, managers) at semiconductor manufacturing sites who do not
directly handle formaldehyde. Therefore, the ONUs are expected to have lower inhalation exposures,
lower vapor-through-skin uptake, and no expected dermal exposure.
3.13.1.3 Inhalation Exposure Estimates
The information and data quality valuation to assess occupational exposures during use of formaldehyde
as a processing aid is listed in Table 3-33 and described in detail below. Table 3-34 summarizes the
monitoring data for use of formaldehyde as a processing aid.
Table 3-33. Processing Aid Inhalation Exposure Data Evaluation
Worker Activity or
Sampling Location
Data Type
Number of
Samples
Overall Data Quality
Determination
Source
Unknown
PBZ monitoring data
191
Medium
(OSHA. 2019)
All 8-hour TWA PBZ samples available were from OSHA's CEHD in the fabricated metal product
manufacturing and the computer and electronic product manufacturing sectors. The methodology for
obtaining and analyzing this data is described in Section 2.5.1.
It should be noted that 9 percent of the 8-hour TWA PBZ, 66 percent of the 15-minute TWA and 47
percent of greater than 15-minute to less than 330-minute, and 68 percent of greater than 14-minute to
less than 60-minute measured below the LOD. To estimate exposure concentrations for this data, EPA
followed the Guidelines for Statistical Analysis of Occupational Exposure Data ( 94a), as
discussed in Section 2.5.1.
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Data is not available to estimate ONU exposures; EPA estimates that ONU exposures are lower than
worker exposures since ONUs do not typically directly handle chemicals. In lieu of ONU-specific data,
EPA uses worker central tendency exposure results as a surrogate to estimate 8-hour TWA exposures for
ONUs.
The high-end and central tendency values for the data represent the 95th and 50th percentile,
respectively. The calculated values are summarized in Table 3-34.
Table 3-34. Summary of Inhalation Exposure Monitoring Data for Processing Aid
Exposure
Concentration
Type
Worker Exposures
Number of
Worker
Samples
ONU
Exposures
Number of
ONU
Samples
Data Quality Rating
of Air
Concentration Data
Central
Tendency
(ppm)
High-End
(ppm)
8-hour TWA
0.04
0.11
35
0.04
N/A
Medium
15-minute
0.09
0.20
32
EPA did not identify
short-term data for ONUs
Medium
>15 to <330
minutes
0.05
0.21
100
Medium
>14 to <60
minutes
0.09
0.23
56
Medium
3.13.1.4 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The maximum concentration assessed for this
OES was 35 percent based on data provided by IPC International via public comment (IPC International.
2019). The minimum concentration reported was 0.1 percent based on data provided by the
Semiconductor Industry Association via public comment (I 20). The calculated occupational
dermal exposures for this OES are 490 |ig/cm2 as the central tendency value and 735 |ig/cm2 as the high-
end value.
3.14 Industrial Use - Non-incorporative Activities - Process Aid in: Oil and
Gas Drilling, Extraction, and Support Activities; Process Aid Specific
to Petroleum Production, Hydraulic Fracturing
3.14.1 Use of Formaldehyde for Oilfield Well Production
3.14.1.1 Process Description
Hydraulic Fracturing
Public comments have identified formaldehyde as a chemical of concern in hydraulic fracturing fluid
(EPF. 2019). Facilities have also self-reported to FracFocus 3.0 that formaldehyde is present in
hydraulic fracturing fluid additives as an inhibitor aid, corrosion inhibitor, friction reducer, bactericide
(Green-Cide 25G), surfactant, acid, breaker, gelling agent, crosslinker, iron cont. (GWPC and IOGCC.
2022)
Hydraulic fracturing stimulates an existing oil or gas well by injecting a pressurized fluid containing
chemical additives into the well ( 2022d). EPA did not find specific container information for
formaldehyde in hydraulic fracturing; however, the ESD on Hydraulic Fracturing indicates that
hydraulic fracturing fluids typically arrive as a liquid in totes, drums, or bulk containers (U.S. EPA.
Page 87 of 313
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2022d). Hydraulic fracturing fluid fomiulations are usually charged to a temporary storage tank, or
fracturing fluid additives are charged to a mixing tank with other additives to formulate the final
fracturing fluid that is injected into the well (U.S. EPA. 2022d).
Once fracturing fluid is formulated to the desired specification, the injection process may begin (
22d). The hydraulic fracturing fluid is pumped into a well bore where it cracks and permeates
the rock below (U.S. EPA. 2022d). A portion of the fracturing fluid, including any chemical additives
such as formaldehyde, may remain in the underground shale formation ( !022d). The
remaining fluid will return to the surface in water that flows back to the surface from the well (U.S.
22d). This is known as flow-back water. Initially, this flow-back water is mostly fracturing
fluid, which includes chemical additives, but as time goes on, it becomes water produced from the rock
formation (U.S. EPA. 2022d).
Wastewater containing chemical additives such as formaldehyde is usually stored and accumulated at
the surface for eventual reuse or disposal ( )22d). Typical storage facilities include open-air
impoundments and closed containers. This wastewater is collected and may be taken to disposal wells,
recyclers, wastewater treatment plants (on- or off-site), or in some cases the water may be left in pits to
evaporate or infiltrate ( '2d).
Traditional Oil Well Production
Traditional oil extraction is comprised of four main steps: (1) exploration, (2) well development,
(3) petroleum production, and (4) site abandonment. The scope of this COU will focus on the petroleum
production portion of the extraction process (QE ).
According to the Emission Scenario Document for Oil Well Production, the main activities typically
involved in petroleum production are bringing the fluid to the surface and separating each component in
the extracted fluid. The extracted mixture is typically first processed to remove the gaseous components,
followed by the removal of solids from the resulting emulsion. The remaining oil-water emulsion is then
further treated to separate the oil.
Petroleum production is typically divided into three stages: primary production, secondary recovery, and
tertiary recovery ( ). Primary production is the first stage of production where natural well
pressure is used to recover oil (OECD. 2012). This segment of the production process usually only
utilizes maintenance chemicals, such as corrosion inhibitors, to protect metallic components of the
piping and well structure (< ). After primary production is no longer feasible, secondary
recovery is then employed (OECD. 2012). This process typically involves the injection of water into the
well to re-pressurize the reservoir. The only chemicals in this stage of the process are those which
remain from primary production (OEt U -). Tertiary recovery is the final stage of petroleum
production which is typically used only when the other methods have been exhausted (OECD.: ).
The chemicals involved in this process may include surfactants, friction reducers, gases, acids, and
proppants (OEC ). The goal of this stage is to modify the physical characteristics of the crude oil
to make it more conducive to flow. The main occupational exposure for petroleum production is
chemical unloading (Figure 3-6) (OEt ).
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Natural Gas
Processing
Solids for
Off-site
Disposal 2
Refinery
3
Deep Well
Injection
(on-shore)
Treatment or
Discharge
(off-shore) 4
Environmental Release:
1. Container residue from raw material released to uncertain media (water, incineration or land)
2. Chemical in solids/sand to off-site disposal (water or land)
3. Chemical in oil to refinery (incineration)
4. Chemical in produced water recycled, deep well injected or discharged (water)
5. Chemical in produced water to irrigation, evaporation and percolation ponds (land)
Occupational Exposure:
A. Dermal exposure to liquid raw material during container unloading
B. Dermal exposure to liquid raw material during container cleaning
C. Dermal exposure to liquid product during equipment and storage tank cleaning
Figure 3-6. Preliminary Process Flow Diagram with Releases and
Exposures for Oil Well Production (OECD, 2012)
3.14.1.2 Worker Activities
Workers are potentially exposed to formaldehyde during oilfield well production during
loading/unloading of liquid raw material from transport containers, during container cleaning, and
during equipment and storage tank cleaning (OECD. 2012). EPA did not find information that indicates
the extent of engineering controls and use of PPE by workers at facilities that perform oilfield well
production operations.
ONUs include employees (e.g., supervisors, managers) at oilfield well production sites who do not
directly handle formaldehyde. Therefore, the ONUs are expected to have lower inhalation exposures,
lower vapor-through-skin uptake, and no expected dermal exposure.
3.14.1.3 Inhalation Exposure Estimates
EPA did not identify inhalation monitoring data to assess exposures during the use of formaldehyde for
oilfield well production OES. Therefore, the Agency estimated inhalation exposures using a Monte
Carlo simulation of models based on the OES. EPA assumed that the formaldehyde-containing hydraulic
fracturing fluid is used in an outdoor process and is used with no engineering controls present. Actual
exposures may differ based on worker activities, formaldehyde throughputs, and facility processes.
For this scenario, EPA applied the EPA/OPPT Mass Balance Inhalation Model to exposure points in the
ESD on Chemicals Used in Hydraulic Fracturing (US. EPA. 2022d). The EPA/OPPT Mass Balance
Inhalation Model estimates the amount of chemical inhaled by a worker during a vapor-generating
activity. EPA estimated the inhalation exposure for the first exposure point using a vapor generation rate
Emulsion Breaker
Gas
Temporary
Storage Tank or
Separation
Process
C
Water
Irrigation,
percolation or
evaporation ponds
(on-shore) 5
Page 89 of 313
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(G) and exposure duration based on the ESD on Chemicals Used in Hydraulic Fracturing (
2022d). EPA calculated vapor generation rates for these exposure points with possible vapor generation
rate models and default values presented in the ESD on Chemicals Used in Hydraulic Fracturing (U.S.
22d). The Monte Carlo simulation varies the following parameters: ventilation rate, mixing
factor, working years, operating days, unloading saturation factor, and air speed.
EPA used the vapor generation rate, exposure duration parameters, and the EPA/OPPT Mass Balance
Inhalation Model to determine a TWA exposure for each exposure point. EPA assumed the same worker
performed each activity throughout their work shift and estimated the 8-hour TWA by combining the
exposures from each exposure point and averaging over 8-hours within the Monte Carlo simulation.
EPA assumed workers had no exposure outside each exposure activity. The high-end values represent
the 95th percentile and the central tendency values represent the 50th percentile of the simulation
outputs. Methods for calculating 8-hour TWA, AC, ADC, and LADC.EPA utilized data reported to the
FracFocus 3.0 database (GWPC and IOGCC. 2022). The concentration data in the database included
concentrations above 60 weight percent formaldehyde. EPA believes it is unlikely that formaldehyde
would be purchased at that concentration as an additive. EPA modeled exposures using two approaches:
first approach did not include data which reported concentrations above 60 percent formaldehyde in the
hydraulic fracturing additive. For the second approach, EPA assume that reporters may be purchasing
formalin as the additive, which would account for 100 percent reported mass concentrations. EPA
adjusted only the mass fractions to convert the concentrations in terms of formaldehyde using weight
percentage of 37 percent formaldehyde in formalin. . These approaches each protect against
unrealistically high reported concentrations of formaldehyde {i.e., 100%) skewing the exposure results.
The exposure results from the first approach are presented in Table 3-35 below, and the second approach
results are presented in Table 3-36. The high-end values represent the 95th percentile and the central
tendency values represent the 50th percentile of the simulation outputs.
Table 3-35. Summary of Inhalation Exposure Modeling Data for the Use of Formaldehyde for
Oilfield Well Production - 60%
Mass Concentration Cap Approach
Exposure Concentration Type
Central Tendency
(ppm)
High-End
(ppm)
Data Quality Rating of Air
Concentration Data
Inhalation exposure during
container unloading or transferring
1.82E-03
2.91E-01
N/A - Modeled data
Container cleaning exposure
1.20E-04
2.79E-04
Equipment cleaning exposure
1.71E-02
4.41E-02
8-Hour TWA (total exposure)
1.02E-05
6.03E-02
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Table 3-36. Summary of Inhalation Exposure Modeling Data for the Use of Formaldehyde for
Oilfield Well Production - 37%
Mass Concentration Adjustment Approach
Exposure Concentration Type
Central Tendency
(ppm)
High-End
(ppm)
Data Quality Rating of Air
Concentration Data
Inhalation exposure during
container unloading or transferring
1.72E-03
3.44E-01
N/A - Modeled data
Container cleaning exposure
1.20E-04
2.79E-04
Equipment cleaning exposure
1.71E-02
4.39E-02
8-Hour TWA (total exposure)
9.34E-06
8.55E-02
EPA did identify one study with slightly higher exposures that measured formaldehyde exposures for
workers adding formaldehyde as a biocide during water injection at an oil well in Norway with a range
of 0.049 to 0.24 ppm (n = 6), and a mean of 0.11 (Stein svag et at.. 2007). While this use is a non-TSCA
activity, the activities may be similar to TSCA activities during oilfield well production.
3.14.1.4 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The maximum concentration assessed for this
OES was 60 percent. Corrosion inhibitors generally arrive in formulations between 10 to 50 percent, but
other types of inhibitors arrive at higher concentrations (OECD, 2012). FracFocus had a large range of
concentrations cited from 0.01 to 100 percent (GWPC and IOGCC, 2022). However, EPA did not
consider this maximum concentrations when calculating dermal exposures as formaldehyde would be in
the gas phase or at elevated temperatures. The calculated occupational dermal exposures for this OES
are 840 |ig/cm2 as the central tendency value and 1,260 |ig/cm2 as the high-end value.
3.15 Industrial Use - Chemical Substances in Industrial Products - Paints
and Coatings; Adhesives and Sealants; Lubricants
EPA has evaluated three OESs:
• Use of coatings, paints, adhesives, or sealants (non-spray applications) and (spray applications)
(see Section 3.5.1);
• Industrial use of lubricants; and
• Foundries.
3.15.1 Industrial Use of Lubricants
3.15.1.1 Process Description
Formaldehyde is used in industrial lubricants in concentrations of greater than 0.2 percent (NICNAS.
2006). Lubricants are used to reduce friction between surfaces in relative motion with each other
(OECD. 2004b). A public comment submitted by the Aerospace Industries Association indicates that
formaldehyde is a component of dry film lubricants, general lubricants, and lubricating oil used in the
aerospace industry ( '019).
EPA did not identify container-specific information on formaldehyde in lubricants; however, EPA
assumes formulations to arrive at the facility in large containers (OECD. 2004b). Conveyor lubricant is a
type of industrial lubricant containing 0.3 percent formaldehyde and is used to provide protection and
Page 91 of 313
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lubrication for conveyor belts made of plastic and steel (NUCHAS. 2006). The lubricant is manually
diluted with water to a formaldehyde concentration of 0.1 percent. The lubricant is continuously
distributed onto the conveyor belt via an enclosed automated system (NICNAS. 2006). After use, the
spent oil may be disposed of in a landfill or incineration, reused as fuel oil, reprocessed, or regenerated
(OECD. 2004b). Lubricants may be replaced every 1 to 5 years, depending on the type of lubricant
(OECD. 2004b). EPA did not identify specific process information for dry film lubricants, general
lubricants, or lubricating oil; although, the Agency expects the process to be similar to conveyor
lubricants.
3.15.1.2 Worker Activities
Workers are potentially exposed to formaldehyde in industrial processes that use formaldehyde as a
lubricant during container unloading and container cleaning (OECD. 2020). EPA did not find
information that indicates the extent of engineering controls and PPE used by workers at facilities that
perform industrial use of lubricants.
ONUs include employees (e.g., supervisors, managers) at industrial use of lubricants sites who do not
directly handle formaldehyde. Therefore, the ONUs are expected to have lower inhalation exposures,
lower vapor-through-skin uptake, and no expected dermal exposure.
3.15.1.3 Inhalation Exposure Estimates
EPA did not identify inhalation monitoring data to assess exposures during industrial use of lubricants.
Therefore, EPA estimated inhalation exposures using a Monte Carlo simulation of models based on the
OES. The Agency assumed that the formaldehyde-containing product arrives at the site in its final
formulation and is used with no engineering controls present. Actual exposures may differ based on
worker activities, formaldehyde throughputs, and facility processes.
For this scenario, EPA applied the EPA Mass Balance Inhalation Model to exposure points in the OECD
ESD on Chemical Additives used in Automotive Lubricants (OECD. 2020). The EPA Mass Balance
Inhalation Model estimates the amount of chemical inhaled by a worker during a vapor-generating
activity. EPA estimated the inhalation exposure for the first exposure point using a vapor generation rate
(G) and exposure duration based on the OECD ESD on Chemical Additives Used in Automotive
Lubricants ( 20). EPA calculated vapor generation rates for these exposure points with
possible vapor generation rate models and default values presented in the OECD ESD on Chemical
Additives used in Automotive Lubricants (OECD. 2020). The Monte Carlo simulation varies the
following parameters: ventilation rate, mixing factor, working years, operating days, unloading
saturation factor, and air speed.
EPA used the vapor generation rate, exposure duration parameters, and the EPA Mass Balance
Inhalation Model to determine a TWA exposure for each exposure point. EPA assumed the same worker
performed each activity throughout their work shift and estimated the 8-hour TWA by combining the
exposures from each exposure point and averaging over 8-hours within the Monte Carlo simulation.
EPA assumed workers had no exposure outside each exposure activity. Table 3-37 summarizes the
estimated 8-hour TWA exposures for use of formulations containing formaldehyde in industrial use of
lubricants based on the two approaches to the second exposure point described above. The high-end
values represent the 95th percentile and the central tendency values represent the 50th percentile of the
simulation outputs.
Page 92 of 313
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Table 3-37. Summary of Inhalation Exposure Mode
ing Data for t
he Industrial Use of Lubricants
Exposure Concentration Type
Central Tendency
(ppm)
High-End
(ppm)
Data Quality Rating of Air
Concentration Data
Inhalation exposure during
container unloading or transferring
4.19E-01
1.50E00
N/A - Modeled data
Container cleaning exposure
2.71E-02
9.94E-02
8-hour TWA (total exposure)
9.70E-03
3.45E-02
3.15.1.4 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. Both the high-end and central tendency dermal
exposures were assessed at a concentration of 0.2 percent based on data from the 2006 formaldehyde
report from the NICNAS (NICNAS. 2006). The calculated occupational dermal exposures for this OES
are 2.8 |ig/cm2 as the central tendency value and 4.2 |ig/cm2 as the high-end value.
3.15.2 Foundries
3.15.2.1 Process Description
Formaldehyde-based phenol resins are used as liquid binding agents to coat sand that is then used in the
core making in the foundry industry ( , ; ; ;
NICNAS. 2006; " 11 s '0; Kominsky and Strom an l,} ). Castings produced by foundries are used in
a wide range of manufactured products. These include vehicles, industrial production equipment, water
and wastewater systems, various piping and valves, railcars and locomotives, military equipment and
vehicles, and household appliances. The resins generally contain less than 0.1 to 1 percent free
formaldehyde ( \iuericaii I'oundrv Society. 2024). (NICNAS. 2006). However, this COU was not
reported in the 2016 or 2020 CDR.
The formaldehyde resin arrives at sand coating sites in large drums (NICNAS. 2006). The resin is
pumped into a mixer and typically mixed with silica sand for 5 minutes (Oliva-Teles et at.. 2009;
NICNAS. 2006). Some sites may decant the resin manually from drums into a measuring cup, then pour
it into the mixer. After mixing, the coated sands are decanted into bags for core-making at foundry sites.
The sand coating is a batch operation, and the frequency may vary depending on the site (NICNAS.
2006).
At foundry sites, iron castings are produced for the manufacture of metal products (Lofstedt et at..
JO I I b; NICNAS. 2006). The coated sand arrives in bags from the sand coating sites and is used to make
solid shape "cores," via a binding system. The cores determine the internal cavities of the casting. Cores
are primarily produced by hot or warm box technology using urea formaldehyde resin. Sand coated with
resin is blown into a hot mold, where the formaldehyde resin melts and acts as a binding agent to form
the core. At larger operations, sand coating and core making may take place in an enclosed system,
where a set dosage of formaldehyde resin is automatically supplied to core-making machines (Lofstedt
et at.. 2011b; Lofstedt et at.. 2011a; Lofstedt et at.. 2009; NICNAS. 2006; NIQSH. 1993).
The urethane cold box process is another widely used process in foundries in the automotive,
transportation, mining, agricultural, and military sectors. This process utilizes liquid phenol-
formaldehyde resins and typically produces cores. Formaldehyde-containing resins are also used in the
following foundry processes: urethane no bake, shell resins, phenolic ester no bake, furan no bake, warm
Page 93 of 313
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box/hot box, and inorganic cold box, and alkyd no bake. These resins typically contain less than 0.1 to 1
percent free formaldehyde (American Foundry Soci 24).
3.15.2.2 Worker Activities
Workers are potentially exposed to formaldehyde during foundry processes during loading/unloading of
transport containers, container and equipment cleaning, during decanting of resin into mixers, and
during core making (NICNAS. 2006). Literature sources stated common engineering controls are
exhaust ventilation systems (McCammon. 1998). EPA did not identify the extent to which workers used
PPE at foundry facilities.
ONUs include employees (e.g., supervisors, managers) at foundry sites who do not directly handle
formaldehyde. Therefore, the ONUs are expected to have lower inhalation exposures, lower vapor-
through-skin uptake, and no expected dermal exposure.
3.15.2.3 Inhalation Exposure Estimates
The information and data quality valuation to assess occupational exposures during the use of
formaldehyde in foundries is listed in Table 3-38 and described in detail below. Table 3-39 summarizes
the monitoring data for foundries.
Table 3-38. Foundries Inhalation Exposure Data Evaluation
Worker Activity or
Sampling Location
Data Type
Number of
Samples
Overall Data Quality
Determination
Source
Operating sand mixer
PBZ monitoring data
1
High
(McCammon. 1998)
Unknown
PBZ monitoring data
1,545
Medium
(OSHA. 2019)
The majority of exposure data came from the OSHA's CEHD in the primary metal and fabricated metal
product manufacturing sectors. The worker activities conducted during the sampling period is unknown.
It should be noted that 6 percent of the 8-hour TWA PBZ, 47 percent of the 15-minute, 14 percent of
greater than 15-minute to less than 330-minute, and 50 percent of greater than 14- to less than 60-minute
samples measured below the LOD. To estimate exposure concentrations for this data, EPA followed the
Guidelines for Statistical Analysis of Occupational Exposure Data ( a), as discussed in
Section 2.5.1.
Data is not available to estimate ONU exposures; EPA estimates that ONU exposures are lower than
worker exposures since ONUs do not typically directly handle chemicals. In lieu of ONU-specific data,
EPA uses worker central tendency exposure results as a surrogate to estimate exposures for ONUs.
The high-end and central tendency values for the data represent the 95th and 50th percentile,
respectively. The calculated values are summarized in Table 3-39.
Page 94 of 313
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Table 3-39. Summary of Inhalation Exposure Monitoring Data for Foundries
Exposure
Concentrati
on Type
Worker Exposures
Number of
Worker
Samples
ONU Exposures
Number
of ONU
Samples
Data Quality
Rating of Air
Concentratio
n Data
Central
Tendency
(ppm)
High-
End
(ppm)
Central
Tendenc
y (ppm)
High-
End
(ppm)
Full shift
8-hour TWA
0.09
0.53
493
0.09
0
Medium
Short-term
15-minute
0.11
0.65
170
EPA did not identify short-
term data for ONUs
Medium
>15 to <330
minutes
0.11
0.66
887
Medium
>14 to <60
minutes
0.10
0.65
212
Medium
EPA identified additional studies with PBZ monitoring data for the use of formaldehyde in foundries
that did not provide the discrete data to be incorporated into the inhalation estimates. These data were
not included in the estimates listed above. In the 2006 formaldehyde NICNAS report, monitoring data
from two Australian foundries ranged from 0.007 to 2.0 ppm for workers involved in foundry core
making (NICNAS. 2006). Three studies measured at facilities in Sweden reported worker exposures at
foundries which use formaldehyde-based resins in core-making (Lofstedt et at < n ,, * s stedt et at..
2009; Westberg et at.. 2005). The monitoring data ranged from 0.0065 to 1.3 ppm for various worker
activities such as core making, die-casting, and molding. Armstrong (2001) measured worker exposures
at a foundry in Malaysia, the arithmetic mean was 0.16 ppm (n = 51).
3.15.2.4 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The maximum concentration assessed for this
OES was 6 percent and the minimum concentration assessed for this OES was 2 percent based on data
from the 2006 formaldehyde report from the NICNAS (NICNAS. 2006). The calculated occupational
dermal exposures for this OES are 84 |ig/cm2 as the central tendency value and 126 |ig/cm2 as the high-
end value.
3.16 Commercial Use - Chemical Substances in Furnishings
Treatment/Care Products - Floor Coverings; Foam Seating and
Bedding Products; Furniture and 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
EPA evaluated the following OESs for this COU:
• Textile finishing, see Section 3.4.1;
• Installation and demolition of formaldehyde-based furnishings and building/construction
materials in residential, public and commercial buildings, and other structures
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3,16,1 Installation and Demolition of Formaldehyde-Based Furnishings and
Building/Construction Materials in Residential, Public and Commercial Buildings,
and Other Structures
3.16.1.1 Process Description
Furnishings and Construction/Building Materials
Formaldehyde-based resins are used as adhesives in the production of wood-based and composite panels
including particleboards, medium-density fiberboard (MDF), oriented strand board (OSB), plywood, and
blockboards (FWIC. 2020; Solenis. 2020; OfFermann. 2017; Kim. :010; NICNAS. 2006).
Concentrations of formaldehyde in the resins used range from less than 0.2 to 0.5 percent (NICNAS.
2006). The maximum concentration identified for this OES was 24 percent both based on formaldehyde
concentration data in construction and building material (Schwensen et at.. 2017). Wood panel products
may be used for shelving, furniture, doors, cabinets, and flooring. Plywood is used in several
commercial applications, such as the construction of residential, commercial, or industrial structures,
building components for homes or other structures, material handling such as pallets, and so-it-yourself
(DIY) structures (NICNAS. 2006).
Wooden boards are cut to size on-site using a circular saw, then fitted and sanded before installation
(NICNAS. 2006; NZ DOH. 1981). The lifespan of plywood, veneers, and wood paneling typically
ranges from 20-100 years before demolition is required ( KB).
Foam and Fiberglass Insulation
Formaldehyde resins may also be present in fiberglass insulation and urea-formaldehyde foam insulation
(NAIMA. 2019; Rossiter and Mathev. 19s \ i m iro Control Inc.. 1983; NIQSH. 1982c. 1980).
According to public comment, final concentrations of formaldehyde in fiberglass insulation are
negligible (NA.I ). EPA believes the use of formaldehyde in urea-formaldehyde foam has
significantly reduced; therefore, it is unlikely to be included in this assessment. EPA also identified that
use of spray polyurethane foam application led to elevated formaldehyde levels. Formaldehyde may be a
trace chemical as it is a feedstock for the production of MDI, which is used in spray polyurethane foam
application(Tiam et at.. 2018).
Phenol-formaldehyde resins are present in fibrous glass insulation used to seal annealing furnace doors
(Price. 1978). Annealing furnaces may be used to relieve stress during the fabrication of steel tank cars
(Price. 1978). Shell plates of stainless steel or carbon steel arrive at the facility in flat form. The plates
are cut, rolled into cylinders, welded, then assembled to form a tank shell. Submerged arc welding is
performed on the seams of the shell. Various fittings, fixtures, and pads are added to the shell via tack
welding, flux-cored arc welding, or stick/wire electrode welding. After the welds are inspected, the tank
car is stress relieved in an annealing furnace. The tank cars may be insulated with fibrous glass by
manually wrapping rolls of the material around the outer wall of the tank and then welding an outer
metal shell over the insulation. Valves, walkways, ladders, rails, and pipes are applied to the tank car.
The car undergoes a final inspection after painting (Price. 1978).
3.16.1.2 Worker Activities
Workers are potentially exposed to formaldehyde during installation and demolition of formaldehyde-
based furnishings and building/construction materials during loading and unloading of transport
containers, cleaning of transport containers, spray application of SPF, foam thickness verification, and
SPF trimming activities ( 021a). EPA did not find information that indicates the extent of
engineering controls and PPE used by workers at facilities that perform installation and demolition of
formaldehyde-based furnishings and building/construction materials.
Page 96 of 313
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ONUs include employees (e.g., supervisors, managers) at installation and demolition of formaldehyde-
based furnishings and building/construction materials sites who do not directly handle formaldehyde.
Therefore, the ONUs are expected to have lower inhalation exposures, lower vapor-through-skin uptake,
and no expected dermal exposure
3.16.1.3 Inhalation Exposure Estimates
The information and data quality valuation to assess occupational exposures during installation and
demolition is listed in Table 3-40 and described in detail below.
Table 3-41 summarizes the monitoring data for installation and demolition of formaldehyde-based
furnishings.
Table 3-40. Installation and Demolition of Formaldehyde-Based Furnishings and
Building/Construction Materials in Residential, Public and Commercial Buildings, and Other
Structures Inhalation Exposure Data Evaluai
tion
Worker Activity or
Sampling Location
Data Type
Number of
Samples
Overall Data Quality
Determination
Source
Unknown
PBZ monitoring data
108
Medium
COSHA. 2019)
All samples were from OSHA's CEHD in the construction sector. The worker activities conducted
during the sampling period is unknown. The methodology for obtaining and analyzing this data is
described in Section 2.5.1.
PBZ data is not available to estimate ONU exposures; EPA estimates that ONU exposures are lower
than worker exposures since ONUs do not typically directly handle chemicals. Several area samples
were provided by sources; however, some of the locations include office buildings and schools
( .aeueretal. 1995; Burretal.. 1993). In these locations EPA does not expect the ONUs to be
installing or demolishing or be in the vicinity immediately after such an activity. Therefore, EPA has not
included these sources in the exposure estimates. In lieu of ONU-specific data, EPA uses worker central
tendency exposure results as a surrogate to estimate exposures for ONUs.
It should be noted that 33 percent of the 8-hour TWA PBZ, 67 percent of the 15-minute, 32 percent of
greater than 15-minute to less than 330-minute, and 67 percent of greater than 14-minute to less than 60-
minute samples measured below the LOD. To estimate exposure concentrations for this data, EPA
followed the Guidelines for Statistical Analysis of Occupational Exposure Data ( 94a). as
discussed in Section 2.5.1.
The high-end and central tendency values for the data represent the 95th and 50th percentile,
respectively. The calculated values are summarized in
Table 3-41.
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Table 3-41. Summary of Inhalation Exposure Monitoring Data for Installation and Demolition of
Formaldehyde-Based Furnishings and Building/Construction Materials in Residential, Public and
Commercial Buildings, and Other Structures
Exposure
Concentration
Type
Worker Exposures
Number
of Worker
Samples
ONU
Exposures
Number
of ONU
Samples
Data Quality
Rating of Air
Concentration
Data
Central
Tendency
(ppm)
High-
End
(ppm)
Full shift
8-hour TWA
0.02
0.12
18
0.02
N/A
Medium
Short-term
15-minute
0.09
0.86
21
EPA did not identify
short-term data for
ONUs
Medium
>15 to <330
minutes
0.04
0.35
69
>14 to <60
minutes
0.09
0.80
24
EPA identified one additional study with PBZ monitoring data for the installation/demolition of
formaldehyde-based furnishings and building/construction materials that did not provide the discrete
data to be incorporated into the inhalation estimates. These data were not included in the estimates listed
above. Tian (Tian et at.. 2018) monitored formaldehyde concentration during and after application of
spray polyurethane foam insulation. The formaldehyde levels were reported to be approximately less
than 0.04 ppm (50 |ig/m3). Formaldehyde was a trace chemical in the formulations used.
Scarselli et al. compiled monitoring data from the Italian information system on occupational
exposure to carcinogens (SIREP). The woodworking machine setters and setter-operators occupational
group had an arithmetic and geometric means of 0.12 ppm and 0.016 ppm, respectively.
In addition, Harlev et al. (7 measured short-term exposures to formaldehyde during the use of
surface cleaners in domestic kitchens and bathrooms. The use of standard surface cleaners resulted in a
geometric mean of 0.013 ppm (n = 50), and the use of "green" surface cleaners resulted in a geometric
mean of 0.011 ppm (n = 50).
3.16.1.4 Weight of Scientific Evidence in Inhalation Exposure Estimates
EPA considered the assessment approach, the quality of the data, and uncertainties in assessment results
to determine a weight of scientific evidence conclusion for the inhalation exposure estimates. The
primary strength is the use of directly applicable monitoring data, which is preferrable to other
assessment approaches such as modeling or the use of OELs/PELs. EPA used PBZ air concentration
data to assess 8-hour inhalation exposures, which have a medium data quality rating from the systematic
review process. The primary limitation of this data includes the uncertainty of the representativeness of
this data toward the true distribution of inhalation concentrations in this scenario, and lack of PBZ and
ONU data. For some of the short-term estimates, more than 50 percent of the samples were below the
LOD. EPA also assumed 8-hour exposure hours per day 250 exposure days per year based on
continuous formaldehyde exposure each working day for a typical worker schedule; it is uncertain
whether this captures actual worker schedules and exposures. Based on these strengths and limitations,
EPA has concluded that the weight of scientific evidence for this assessment is moderate for full shift
and short-term exposure estimates and provides a plausible estimate of exposures.
Page 98 of 313
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3.16.1.5 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The maximum concentration assessed for this
OES was 24 percent, and the minimum concentration identified was 0.004 percent, both based on
formaldehyde concentration data in construction and building material (Schwensen et al., 2017). The
calculated occupational dermal exposures for this OES are 336 |ig/cm2 as the central tendency value and
504 |ig/cm2 as the high-end value.
3.17 Commercial Use - Chemical Substances in Treatment Products -
Water Treatment Products
3.17.1 Use of Formulations containing Formaldehyde for Water Treatment
COU: Commercial uses - chemical substances in treatment products - water treatment products.
3.17.1.1 Process Description
In the 2016 CDR, two reporters indicated the commercial use of formaldehyde as a liquid in water
treatment products ( ). One facility reported 6 percent of its PV towards this use with a
formaldehyde concentration of less than 1 percent by weight. The other facility reported 28 percent of its
PV with a concentration of 1 to less than 30 percent by weight ( ). This condition of use
was not reported in the 2020 CDR. A safety data sheet (SDS) by CHEMetrics indicates the use of
formaldehyde in water testing kits with a concentration of 0.1 to 0.2 percent by weight (CHEMetrics.
2018). Another SDS by CHEMTREC- indicates the use of formaldehyde as a waste treatment liquid
chemical, although a concentration was not provided (Koch Turf.! ). Water treatment facilities may
use formulations containing 37 to 40 percent formaldehyde as an additive to sanitize the facility,
although that use would be a non-TSCA use (NICNAS. 2006).
EPA did not find any container-specific information on formaldehyde in water treatment products.
According to the GS on Water Treatment Disinfectants, other disinfectant chemicals arrive at water
treatment sites in a tank car or tank truck (U.S. EPA. 1994c). The Agency assumes the formaldehyde for
non-pesticidal water treatment to arrive similarly. EPA expects that formaldehyde formulation will
arrive, be unloaded then distributed for use in water systems.
3.17.1.2 Worker Activities
Workers are potentially exposed to formaldehyde during the use of formulations containing
formaldehyde for water treatment during equipment cleaning, loading/unloading of containers, and
process activities such as pulling solids from the bar screener (Dow Chemical. 2017b). EPA did not
identify any information to indicate the extent to which workers used PPE in water treatment.
ONUs include employees (e.g., supervisors, managers) at water treatment sites who do not directly
handle formaldehyde. Therefore, the ONUs are expected to have lower inhalation exposures, lower
vapor-through-skin uptake, and no expected dermal exposure.
3.17.1.3 Inhalation Exposure Estimates
EPA did not identify inhalation monitoring data to assess exposures during use of formulations
containing formaldehyde for water treatment. Therefore, EPA estimated inhalation exposures during
water treatment products using the Tank Truck and Railcar Loading and Unloading Release and
Inhalation Exposure Model. A detailed discussion of this model can be found in Appendix C.7
Page 99 of 313
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Table 3-42 summarizes the estimated full shift TWA exposures for use of formulations containing
formaldehyde in for water treatment based on the Tank Truck and Rail car Loading and Unloading
Release and Inhalation Exposure Model. The high-end values represent the 95th percentile and the
central tendency values represent the 50th percentile of the model outputs.
Table 3-42. Summary of Inhalation Exposure Modeling Data for the Use of Formulations
Containing Formaldehyde for Water Treatment
Exposure Concentration Type
Central Tendency
(ppm)
High-End
(ppm)
Data Quality Rating of Air
Concentration Data
Acute TWA
0.619
1.24
N/A - Modeled data
8-hour TWA
0.0383
0.155
N/A - Modeled data
3.17.1.4 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The maximum concentration assessed for this
OES was 40 percent with the assumption of a concentrated formaldehyde solution used and diluted for
water treatment purposes. The calculated occupational dermal exposures for this OES are 560 |ig/cm2 as
the central tendency value and 840 |ig/cm2 as the high-end value.
3.18 Commercial Use - Chemical Substances in Treatment/Care Products -
Laundry and Dishwashing Products
3,18.1 Use of Formulations Containing Formaldehyde in Laundry and Dishwashing
Products
COU: Commercial uses - chemical substances in treatment products - water treatment products.
3.18.1.1 Process Description
Laundry Products
SDSs have iaentmed the use of formaldehyde in liquid laundry detergent and fabric softener (Colgate-
Palmolive Company. 2016b; Phoenix Brands. 2007). The concentration of formaldehyde was not
indicated in these SDSs. This COU was not reported in the 2020 or 2016 CDR. In the United States,
laundry facilities can be classified into two main categories—industrial and institutional (OECD.
2011c). Industrial laundries wash soiled laundry received from hospitals, repair shops, doctor's offices,
and other customers. Institutional laundries are located within a hospital, nursing home, hotel, or other
institutional facilities (J ).
EPA did not find container-specific information for formaldehyde in industrial or institutional laundry
detergents. The ESD on Water Based Washing Operations at Industrial and Institutional Laundries
indicates that industrial laundry detergents typically arrive as a liquid or powder in drums, totes, or bulk
tanker trucks (OECD. , ). The ESD also indicates that institutional laundry detergents typically
arrive as a liquid or powder in 5-galIon pails (OECD. 2011c). For both types of laundries, the soiled
laundry is loaded into mechanical washers, and the laundry is washed using water and a detergent
appropriate for the item type and soil loading (OECD. z ). Washing may be completed in cycles or a
continuous process (OI ). The washing machine generally rinses the laundry after washing to
remove most of the wash chemicals ( ). Wastewater is transferred down drains to a POTW
(( ).
Page 100 of 313
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Dishwashing Products
An SDS identified formaldehyde in consumer liquid hand soap in concentrations ranging from 0 to 0.1
percent (Colgate-Palmolive Company. 2016a). EPA did not find any container-specific information on
formaldehyde in hand soaps or other dishwashing products; however, the Agency expects formulation to
arrive as a liquid in small containers of various sizes. EPA did not identify any process-specific
information for formaldehyde in dishwashing products. In an occupational setting, the Agency expects
hand soaps to be used when a worker washes their hands. Dirty water containing the used hand soap is
expected to be rinsed down sink drains to POTWs. Similarly, EPA expects dishwashing soap to be used
when a worker washes dishes. Water containing the used dishwashing soap is expected to be rinsed
down sink drains to POTWs. The number and location of sites that use dishwashing products containing
formaldehyde are unknown. EPA expects facilities using dish washing products to operate up to 7 days
per week, although it is uncertain that formaldehyde is used every day.
3.18.1.2 Worker Activities
Workers are potentially exposed to formaldehyde during the use of formulations containing
formaldehyde in laundry and dishwashing products during loading\unloading activities, spot cleaning,
and fabric pressing activities (Ceballos et at.. 2016). EPA did not identify any information to indicate the
extent to which workers used PPE in laundry and dishwashing sites.
ONUs include employees (e.g., supervisors, managers) at laundry and dishwashing sites who do not
directly handle formaldehyde. Therefore, the ONUs are expected to have lower inhalation exposures,
lower vapor-through-skin uptake, and no expected dermal exposure.
3.18.1.3 Inhalation Exposure Estimates
The information and data quality valuation to assess occupational exposures during use of laundry and
dishwashing products is listed in Table 3-43 and described in detail below.
Table 3-44 summarizes the data for use of formulations containing formaldehyde in laundry and
dishwashing products.
Table 3-43. Use of Formulations Containing
formaldehyde in Laundry and Dishwashing Products
Worker Activity or
Sampling Location
Data Type
Number of
Samples
Overall Data Quality
Determination
Source
Pressing fabrics, unloading
and loading fabrics from dry
cleaning machine
PBZ monitoring
data
12
High
(Ceballos et ah,
2016)
Unknown
PBZ Monitoring
Data
1
Medium
(OSHA. 2019)
Data for 15-minute was not available to estimate worker exposures. Discrete short-term PBZ samples
were available in the OSHA CEHD database for a tailoring shop. EPA has assigned that data to the
laundry and dishwashing products as formaldehyde has been reported in dry cleaning solvents. All 8-
hour TWA samples came from two papers that investigated fabric cleaning and dry-cleaning shops
(Ceballos et at.. .^ s , ^ I alios et at.. 2015). EPA did not identify occupational monitoring data for
industrial or institutional laundries or facilities with heightened use of dishwashing products.
Formaldehyde is reactive in water, so the potential for formaldehyde exposure from these uses may be
limited, there is some uncertainty in the use of monitored data for dry cleaning to be applicable for
water-based laundry and dishwashing products.
Page 101 of 313
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Data is not available to estimate ONU exposures; EPA estimates that ONU exposures are lower than
worker exposures since ONUs do not typically directly handle chemicals. In lieu of ONU-specific data,
the Agency uses worker central tendency exposure results as a surrogate to estimate 8-hour TWA
exposures for ONUs.
It should be noted that 12 of the 8-hour TWA PBZ and one of the short-term samples measured below
the LOD. To estimate exposure concentrations for this data, EPA followed the Guidelines for Statistical
Analysis of Occupational Exposure Data (U. 4a), as discussed in Section 2.5.1.
The high-end and central tendency values for the 8-hour TWA data represent the 95th and 50th
percentile, respectively. The calculated values are summarized in Table 3-44.
Table 3-44. Summary of Inhalation Exposure Monitoring Data for Use of Formulations
Containing Formaldehyde in Laundry and Dishwashing Products
Exposure
Concentration
Type
Worker Exposures
Number
of
Worker
Samples
ONU
Exposures
Number of
ONU
Samples
Data Quality
Rating of Air
Concentration
Data
Central
Tendency
(ppm)
High-
End
(ppm)
Full shift
8-hour TWA
0.01
0.01
12
0.01
0
Medium to High
Short-term
15-minute TWA
EPA did not identify 15-minute
data for workers
EPA did not identify 15-
minute data for ONUs
4-hour(240
minutes)
0.13
1
EPA did not identify
short-term data for
ONUs
3.18.1.4 Dermal Exposure Results
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The high-end and central tendency dermal
exposures were both assessed using a concentration of 4 percent based on the Emission Scenario
Document on the Chemicals Used in Water Based Washing Operations at Industrial and Institutional
Laundries ( ). The calculated occupational dermal exposures for this OES are 56 |ig/cm2 as
the central tendency value and 84 |ig/cm2 as the high-end value.
3.19 Commercial Use - Chemical Substances in Construction, Paint,
Electrical, and Metal Products - Adhesives and Sealants; Paints and
Coatings
EPA has evaluated two OESs:
• Use of coatings, paints, adhesives, or sealants (non-spray applications), see Section 3.5.1; and
• Use of coatings, paints, adhesives, or sealants (spray applications), see Section 3.5.1.
Page 102 of 313
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3.20 Commercial Use - Chemical Substances in 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
EPA has evaluated one OES:
• Installation and demolition of formaldehyde-based furnishings and building/construction
materials in residential, public and commercial buildings, and other structures, see Section
3.16.1.
3.21 Commercial Use - Chemical Substances in Electrical Products -
Machinery, Mechanical Appliances, Electrical/Electronic Articles;
Other Machinery, Mechanical Appliances, Electronic/Electronic
Articles
3.21.1 Use of Electronic and Metal Products
3.21.1.1 Process Description
Formaldehyde is used to manufacture printed circuit boards, which are found in virtually all electronic
products, including televisions, computers, printers, phones, weapons systems, and aerospace hardware
(Schripp and Wen si )9; LaDou. 2006). The 2020 CDR cites use of formaldehyde as an
intermediate in electronics ( )20a). Electrical and electronic products may be used in a
variety of occupational settings, such as repair shops, office buildings, copy centers, and electronic
waste recycling centers (Vicente et at.. 2017; Schripp and Wen sing. 2009; Klincewicz and Reh. 1989).
The concentration of formaldehyde in electronic products is unknown; although, public comments report
a negligible amount of formaldehyde in electronics (IPC International. 2020; 320). EPA did not
identify any process information related to the use of metal products containing formaldehyde.
3.21.1.2 Worker Activities
Workers may potentially be exposed to formaldehyde during use of electronic and metal products during
equipment cleaning. EPA did not identify information that indicates the extent of engineering controls
and PPE used by workers at facilities that perform use of electronic and metal product operations.
ONUs include employees (e.g., supervisors, managers) at use of electronic and metal products sites who
do not directly handle formaldehyde. Therefore, the ONUs are expected to have lower inhalation
exposures, lower vapor-through-skin uptake, and no expected dermal exposure.
3.21.1.3 Inhalation Exposure Estimates
The information and data quality valuation to assess occupational exposures during use of electronic and
metal products is listed in Table 3-45 and described in detail below. Table 3-46 summarizes the
monitoring data for the use of electronic and metal products containing formaldehyde.
Page 103 of 313
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Table 3-45. Use of Electronic and Metal Products Inhalation Exposure Data Eva
uation
Worker Activity or
Sampling Location
Data Type
Number of
Samples
Overall Data Quality
Determination
Source
Unknown
PBZ monitoring data
81
Medium
(OSHA. 2019)
All of the monitoring data were from OSHA's CEHD. OSHA sampled companies within the
professional, scientific, and technical services sector as well as the electrical equipment, appliance and
component manufacturing sector. The methodology for obtaining and analyzing this data is described in
Section 2.5.1.
It should be noted that 3 percent of the 8-hour TWA PBZ, 18 percent of the 15-minute, 20 percent of
greater than 15-minute to less than 330-minute and 25 percent of greater than 14-minute to less than 60-
minute samples measured below the LOD. To estimate exposure concentrations for this data, EPA
followed the Guidelines for Statistical Analysis of Occupational Exposure Data ( 94a). as
discussed in Section 2.5.1.
Data is not available to estimate ONU exposures; EPA estimates that ONU exposures are lower than
worker exposures since ONUs do not typically directly handle chemicals. In lieu of ONU-specific data,
EPA uses worker central tendency exposure results as a surrogate to estimate exposures for ONUs for
the 8-hour TWA estimates.
The high-end and central tendency values for the data represent the 95th and 50th percentile,
respectively. The calculated values are summarized in Table 3-46.
Table 3-46. Summary of Inhalation Exposure Monitoring Data for Use of Electronic and Metal
Products
Exposure
Concentration
Type
Worker Exposures
Number of
Worker
Samples
ONU
Exposures
Number of
ONU
Samples
Data Quality
Rating of Air
Concentration
Data
Central
Tendency
(ppm)
High-
End
(ppm)
Full shift
8-hour TWA
0.06
0.51
29
0.06
N/A
Medium
Short-term
15-minute
0.38
1.14
17
EPA did not identify
short-term data for ONUs
Medium
>15 to <330
minutes
0.09
0.34
35
Medium
>14 to <60
minutes
0.37
1.10
20
Medium
3.21.1.4 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The maximum concentration assessed for this
OES was 40 percent, and the minimum concentration identified was 20 percent, both based on data from
the Emission Scenario Document on Photoresist Use in Semiconductor Manufacturing ( ).
The calculated occupational dermal exposures for this OES are 560 |ig/cm2 as the central tendency value
and 840 |ig/cm2 as the high-end value.
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3.22 Commercial Use - Chemical Substances in Metal Products -
Construction and Building Materials Covering Large Surface Areas,
Including Metal Articles
EPA has evaluated one OES:
• Use of electronic and metal products, see Section 3.21.1.
3.23 Commercial Use - Chemical Substances in Automotive and Fuel
Products - Automotive Care Products; Lubricants and Greases; Fuels
and Related Products
EPA has evaluated three OESs:
• Use of formulations containing formaldehyde in automotive care products;
• Use of automotive lubricants; and
• Use of formulation containing formaldehyde in fuels.
3,23.1 Use of Formulations Containing Formaldehyde in Automotive Care Products
COU: Commercial uses - chemical substances in automotive and fuel products - automotive care
products; lubricants and greases; fuels and related products.
3.23.1.1 Process Descriptions
EPA did not identify formaldehyde-specific process information on automotive care products.
According to the Automotive Detailing Methodology Review (MRD), automotive detailing products
arrive at facilities in small containers ranging from 4 ounces to 15 gallons ( 322b). Products
may be applied directly onto the car or application equipment (e.g., cloths, buffer pads) or diluted with
water in a bucket before use. Before polishing and other detailing processes, the exterior of the vehicle
to be detailed is washed, typically with a hose, bucket, and sponge. The interior of the vehicle may also
be cleaned using compressed air to loosen dirt and then vacuum. Detailers may apply a protective
coating to vinyl or leather surfaces by wiping the coating onto surfaces and removing excess coating
with cloths. Carpet and upholstery are cleaned by pre-treating stains, then using portable carpet cleaning
machines. Upon completion of the detailing process, the vehicle is returned to the customer (U.S. EPA.
2022b).
3.23.1.2 Worker Activities
Workers are potentially exposed to formaldehyde during the use of formulations containing
formaldehyde in automotive care products during unloading chemicals from transport containers and the
application and use of automotive detailing products ( 022b). EPA did not identify any
information to indicate the extent to which worker PPE is used in automotive care sites.
ONUs include employees (e.g., supervisors, managers) at automotive care sites who do not directly
handle formaldehyde. Therefore, the ONUs are expected to have lower inhalation exposures, lower
vapor-through-skin uptake, and no expected dermal exposure.
3.23.1.3 Inhalation Exposure Estimates
EPA did not identify inhalation monitoring data to assess exposures during use of formulations
containing formaldehyde in automotive care products. Therefore, EPA estimated inhalation exposures
using a Monte Carlo simulation of models based on the OES. The Agency estimated inhalation
exposures of formaldehyde by simulating two possible scenarios. EPA assumed that the formaldehyde-
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containing product arrives at the site in its final formulation and is used with no engineering controls
present. Actual exposures may differ based on worker activities, formaldehyde throughputs, and facility
processes.
For this scenario, the Agency applied the EPA Mass Balance Inhalation Model to the first exposure
point (Transfer Operation Exposures from Unloading Transport Containers) described in the GS on
Commercial Use of Automotive Detailing Products ( 22b). The EPA Mass Balance
Inhalation Model estimates the amount of chemical inhaled by a worker during a vapor-generating
activity. EPA estimated the inhalation exposure for the first exposure point using a vapor generation rate
(G) and exposure duration based on the GS on Commercial Use of Automotive Detailing Products (U.S.
22b). EPA calculated vapor generation rates for the first exposure point with possible vapor
generation rate models and default values presented in the GS. For the second exposure point
(Application and Use of Automotive Detailing Products), the Agency applied two approaches. The first
was using industry monitoring data for total volatile organic compounds (TVOCs) cited in the GS. The
second was assuming that all of the formaldehyde in the applied detailing product evaporates over the
duration of the activity, and thus a vapor generation rate could be calculated and applied in the EPA
Mass Balance Inhalation Model. The Monte Carlo simulation varies the following parameters:
ventilation rate, mixing factor, saturation factor, loss factor, container sizes, working years, operating
and exposure days, formaldehyde concentration in the auto detailing product, annual number of cars
detailed per site, use rate of automotive detailing product per car, and mass concentration of
formaldehyde in air for the second exposure point based on industry data cited in the GS.
EPA used the vapor generation rate, exposure duration parameters, and mass concentration of
formaldehyde in air for the second exposure point from the GS on Commercial Use of Automotive
Detailing Products ( 22b) and the EPA Mass Balance Inhalation Model to determine a
TWA exposure for each exposure point. The Agency assumed the same worker performed each activity
throughout their work shift and estimated the 8-hour TWA by combining the exposures from each
exposure point and averaging over 8 hours within the Monte Carlo simulation. EPA assumed workers
had no exposure outside each exposure activity. Table 3-47 summarizes the estimated full shift TWA
exposures for use of formulations containing formaldehyde in automotive care products based on the
two approaches to the second exposure point described above. The high-end values represent the 95th
percentile and the central tendency values represent the 50th percentile of the simulation outputs.
Table 3-47. Summary of Inhalation Exposure Modeling Data for the Use of Formulations
Containing Formaldehyde in Automotive Care Products
Modeled
Scenario
Exposure Concentration
Type
Central
Tendency (ppm)
High-End (ppm)
Data Quality Rating of
Air Concentration Data
Scenario 1:
Industry Data for
Exposure Point 2
Transfer operation
exposures from unloading
transport containers
3.26E-02
1.3E00
N/A - Modeled data
Application and use of
automotive detailing
products
4.72E-01
3.01E00
Full shift TWA exposure
concentration (total
exposure)
2.97E-01
1.51E00
Scenario 2:
Complete
Evaporation for
Transfer operation
exposures from unloading
transport containers
3.22E-02
1.3E00
Page 106 of 313
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Modeled
Scenario
Exposure Concentration
Type
Central
Tendency (ppm)
High-End (ppm)
Data Quality Rating of
Air Concentration Data
Exposure Point 2
Application and use of
automotive detailing
products
8.62E-01
2.81E01
Full shift TWA exposure
concentration (total
exposure)
4.38E-01
1.41E01
3.23.1.4 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The maximum concentration assessed for this
OES was 30 percent, and the minimum concentration assessed was 1 percent based on reporting data for
this OES in the 2020 CDR ( )20a). While there were reporters which reported in ranges up
to 60 percent in the 2016 CDR, formaldehyde is not expected to be present in this concentration in
automotive care products based on the 2020 reporting data ( ). High-end dermal
exposures are calculated based on a higher amount of formaldehyde remaining on skin upon immersion
(10.3 mg/cm2 per event), and the central tendencies are based on a lower amount of formaldehyde
remaining on skin upon immersion (3.8 mg/cm2 per event). The maximum concentration was used for
both high-end and central tendency calculations. The calculated occupational dermal exposures for this
OES are 1,140 |ig/cm2 as the central tendency value and 3,090 |ig/cm2 as the high-end value.
3.23.2 Use of Automotive Lubricants
COU: Commercial uses - chemical substances in automotive and fuel products - automotive care
products; lubricants and greases; fuels and related products.
3.23.2.1 Process Description
Formaldehyde is present in lubricants that may be used in the automotive industry (NICNAS. 2006). A
lubricant is defined as a material used to reduce friction between surfaces in relative motion with each
other (OECD. 2020). In the automotive industry, lubricants are used in gasoline and diesel engines. This
COU was not reported in the 2016 or 2020 CDR. The formaldehyde concentration in automotive greases
and lubricants is unknown. Based on the ESD on Chemical Additives Used in Automotive Lubricants,
default concentration values for lubricant additives range from 0.1 to 20 percent (QE )20).
EPA did not find any container-specific information on formaldehyde in automotive lubricants;
however, EPA expects lubricants to arrive at automotive service facilities in 5-gallon or smaller
containers. EPA did not identify process-specific information for formaldehyde in automotive
lubricants. According to the ESD on Automotive Lubricants, the lubricant is directly injected into the
engine of the vehicle (OECD. 2020). It is estimated that 25 percent of the lubricants in passenger cars
and commercial vehicles are consumed during use. Most of the used lubricant is present in the exhaust
gases as either combustion products or particulates. The remaining spent lubricant is either recycled for
the use of in-house heating, reused for fuel oil after further treatment, or disposed of as municipal waste.
The frequency of oil changes is specified by the vehicle manufacturer, typically depending on factors
such as vehicle mileage and extent of use.
3.23.2.2 Worker Activities
Workers are potentially exposed to formaldehyde during use of automotive lubricants during
loading/unloading of transport containers, equipment cleaning, and direct injection of lubricant into the
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engine (OECD. 2020). EPA did not identify information that indicates the extent of engineering controls
and PPE used by workers at facilities that perform use of automotive lubricant operations.
ONUs include employees (e.g., supervisors, managers) at use of automotive lubricant sites who do not
directly handle formaldehyde. Therefore, the ONUs are expected to have lower inhalation exposures,
lower vapor-through-skin uptake, and no expected dermal exposure.
3.23.2.3 Inhalation Exposure Estimates
The information and data quality valuation to assess occupational exposures during use of automotive
lubricants is listed in Table 3-48 and described in detail below. Table 3-49 summarizes the monitoring
data for use of automotive lubricants containing formaldehyde.
Table 3-48. Use of Automotive Lubricants In
lalation Exposure Data Evaluation
Worker Activity or
Sampling Location
Data Type
Number of
Samples
Overall Data
Quality
Determination
Source
Unknown
PBZ monitoring data
30
Medium
(OSHA. 2019)
All worker samples available were from OSHA's CEHD. OSHA sampled companies within the
transportation equipment manufacturing, fabricated metal product manufacturing, and repair and
maintenance sector. The methodology for obtaining and analyzing this data is described in Section 2.5.1.
It should be noted that 33 percent of 8-hour TWA samples and 71 percent of the greater than 15-minute
to less than 330-minute samples were below the detection limit. All six of the greater than 14-minute to
less than 60-minute are below the detection limit.
Data is not available to estimate ONU exposures; EPA estimates that ONU exposures are lower than
worker exposures since ONUs do not typically directly handle chemicals. In lieu of ONU-specific data,
EPA uses worker central tendency exposure results as a surrogate to estimate exposures for ONUs.
The high-end and central tendency values for the data represent the 95th and 50th percentile,
respectively. The calculated values are summarized in Table 3-49.
Table 3-49. Summary of Inhalation Exposure Monitoring Data for the Use of Automotive
Lubricants
Exposure
Concentration
Type
Worker Exposures
Number
of
Worker
Samples
ONU
Exposures
Number of
ONU
Samples
Data Quality
Rating of Air
Concentration
Data
Central
Tendency
(ppm)
High-
End
(ppm)
Full shift
8-hour TWA
0.03
0.03
6
0.03
N/A
Medium
Short-term
>15 to <330
minutes
0.03
0.09
24
No short-term ONU data
Medium
>14 to <60
minutes
<0.12 (LOD)
6
Medium
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EPA did not identify any non-discrete PBZ data for workers or ONUs during the use of automotive
lubricants.
3.23.2.4 Dermal Exposure Results
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The Agency did not identify concentration
specific to formaldehyde use for these COUs. EPA assessed at a concentration of 20 percent based on
data from the Emission Scenario Document on Chemical Additives Used in Automotive Lubricants
(OECD. 2020). The calculated occupational dermal exposures for this OES are 280 |ig/cm2 as the
central tendency value and 420 |ig/cm2 as the high-end value.
3.23.3 Use of Formulations containing Formaldehyde in Fuels
COU: Commercial uses - chemical substances in automotive and fuel products - automotive care
products; lubricants and greases; fuels and related products.
3.23.3.1 Process Description
Formaldehyde may be emitted during the combustion of unleaded gasoline (Geivanidis et at.. 2003; EC.
2000). EPA did not identify process-specific information besides scenarios where formaldehyde is
produced during the combustion of gasoline.
3.23.3.2 Worker Activities
Workers are potentially exposed to formaldehyde during the use of formulations containing
formaldehyde in fuels during gas station activities, loading/unloading, and the fueling of vehicles
(Shimohara et at.. 2019; Maiumdar (nee som) et at.. 2008; Davis et at.. 2007). EPA did not identify any
information to indicate the extent to which worker PPE is used in processes using formaldehyde in fuels.
ONUs include employees (e.g., supervisors, managers) at fuel use sites who do not directly handle
formaldehyde. Therefore, the ONUs are expected to have lower inhalation exposures, lower vapor-
through-skin uptake, and no expected dermal exposure.
3.23.3.3 Inhalation Exposure Estimates
The information and data quality valuation to assess occupational exposures during use of formulations
containing formaldehyde in fuels is listed in Table 3-50 and described in detail below. Table 3-51
summarizes the monitoring data for use of formulations containing formaldehyde in fuels.
Table 3-50. Use of Formulations Containing Formaldehyde in Fuels Inhalation Exposure Data
Evaluation
Worker Activity or
Sampling Location
Data Type
Number of
Samples
Overall Data Quality
Determination
Source
Unknown
PBZ monitoring data
19
Medium
(OSHA. 2019)
OSHA sampled one company in the petroleum bulk stations and terminals subsector. The methodology
for obtaining and analyzing this data is described in Section 2.5.1.
Data is not available to estimate ONU exposures; EPA estimates that ONU exposures are lower than
worker exposures since ONUs do not typically directly handle chemicals. In lieu of ONU-specific data,
EPA uses worker central tendency exposure results as a surrogate to estimate exposures for ONUs.
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It should be noted that one of the 8-hour TWA, one of the 15-minute, two of greater than 15-minute to
less than 330-minute and one of the greater than 14-minute to less than 60-minute samples measured
below the LOD. To estimate exposure concentrations for this data, EPA followed the Guidelines for
Statistical Analysis of Occupational Exposure Data (U. 4a), as discussed in Section 2.5.1.
The high-end and central tendency values for the data represent the 95th and 50th percentile,
respectively. The calculated values are summarized in Table 3-51.
Table 3-51. Summary of Inhalation Exposure Monitoring Data for the Use of Formulations
Exposure
Concentration
Type
Worker
Exposures
Number
of
Worker
Samples
ONU
Exposures
Number of
ONU
Samples
Data Quality
Rating of Air
Concentration
Data
Central
Tendenc
y (ppm)
High-
End
(ppm)
Full shift
8-hour TWA
0.26
0.35
3
0.26
N/A
Medium to High
Short-term
15-minute
1.63
2.53
8
EPA did not
identify short-
term data for
ONUs
N/A
Medium
>15 to <330
minutes
0.26
1.15
8
N/A
Medium
>14 to <60
minutes
1.63
2.53
8
N/A
Medium
EPA identified additional studies with PBZ monitoring data for the use of formulations containing
formaldehyde in fuels that did not provide the discrete data to be incorporated into the inhalation
estimates. These data were not included in the estimates listed above.
In the United States, studies have monitored formaldehyde at gas stations. Within the OSHA CEHD
data, a facility under NAICS 447110 Gasoline Stations with Convenience Stores measured two area
samples at 0.07 and 0.11 ppm in 1998. More recent studies have reported lower exposures, Davis et al.
(2007) collected 8-hour TWA monitoring data from truck transport operations in the United States, with
arithmetic means ranging between 0.0068 and 0.0078 and medians ranging between 0.0058 and 0.0066
ppm. I.T. Corporation {, 1995, 2859246} monitored at full-serve fuel stations in New Jersey with a
range of 0.008 to 0.035 ppm in the areas in the perimeter and near the gas pumps.
Monitoring data conducted in sites in other countries reported lower concentrations during use of fuels
at gas stations. In 2019, Shinohara et took short-term measurements of gas station employees
in Japan during the refueling processing, which resulted in arithmetic means concentrations of 0.0041
and 0.0094 ppm. Another study conducted in Korea measured 8-hour TWA concentrations of gas station
workers and resulted in a much higher exposure concentration with an arithmetic mean of 0.75 ppm. A
study conducted in Thailand by Kitwattanavong et al. measured petrol station attendants and
resulted in an exposure range between 0.0062 and 0.015 ppm (Kitwattanavong et al.. 2013). Sousa et al.
measured short-term exposures for gas station attendants in Brazil between 2009 and 2010,
which resulted in an arithmetic mean of 0.011 ppm.
EPA identified non-discrete PBZ data for ONUs working as gas station employees from Shinohara
(Shinohara et al.. 2019). The short-term data resulted in arithmetic means of 0.0082 and 0.02 ppm. The
study stated that the higher indoor formaldehyde concentrations are thought to be from off-gassing of
plywood and wallpaper adhesives.
Page 110 of 313
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3.23.3.4 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The maximum concentration assessed for this
OES was 0.15 percent, based on the 2016 CDR for fuels and related products (<1%) and the MRD on
the Use of Fuels ( v << \ .0.1*1. J016). The calculated occupational dermal exposures for this OES
are 2.1 |ig/cm2 as the central tendency value and 3.15 |ig/cm2 as the high-end value.
3.24 Commercial Use - Chemical Substances in Agriculture Use Products -
Lawn and Garden Products
3.24.1 Use of Fertilizers Containing Formaldehyde in Outdoors Including Lawns
3.24.1.1 Process Description
Formaldehyde is used in the production of three type of fertilizers: solid urea and slow-release ureaform
solid or liquid fertilizers. In both products, formaldehyde is used as a reactant/intermediate in the
process with only impurity levels of formaldehyde in fertilizer products. End users of controlled-release
fertilizers include agricultural, horticultural, landscaping, and consumer markets (EC ). The
2020 CDR indicates a formaldehyde concentration of less than 1 percent (I v << \ - '20a). Fertilizer
SDSs indicate formaldehyde concentrations below 0.1 percent.
For corn production, urea-based fertilizer is applied one to two times per year for a farm, which may be
applied by a farmer or by commercial applicators. A public commenter noted that the cleaning of
equipment would be unneeded for agricultural applications. The application of the fertilizer may occur
with the use of cabs during application (EPA-HQ-OPPT-2023-0613-0216).
Fertilizers can arrive as a liquid or dry granulated material (Koch Turf. 2016). EPA assumes commercial
containers for fertilizer may be similar to those of agricultural pesticides. According to the GS on
Application of Agricultural Pesticides, liquid formulations may arrive in reusable plastic or metal
containers of several gallons ( 3). Solid products may arrive in paper, plastic, or cardstock
containers ( 3). The application depends on a variety of factors including crop type, soil
type, and climate. Common application techniques include surface broadcasting, incorporation into the
soil using attachments to plow, and injection of liquid/gaseous formulations by pumping through
cultivator knives (Taylor. 2004). Dry granulated formaldehyde fertilizers are either broadcast or
suspended in water and root-zone injected or spray-applied (Koch Turf. 2016).
3.24.1.2 Worker Activities
Workers are potentially exposed to formaldehyde during use of fertilizers containing formaldehyde
during unloading of transport containers, application of fertilizer to lawn, and equipment cleaning. EPA
did not identify information that indicates the extent of engineering controls and PPE used by workers
that perform use of formulations containing formaldehyde in outdoors including lawn operations. Some
workers may be certified pesticide applicators and may be applying pesticide with fertilizers, with the
level of PPE dictated by the pesticide label.
ONUs include employees (e.g., supervisors, managers) at use of formulations containing formaldehyde
in outdoors including lawn sites who do not directly handle formaldehyde. Therefore, the ONUs are
expected to have lower inhalation exposures, lower vapor-through-skin uptake, and no expected dermal
exposure.
Page 111 of 313
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3.24.1.3 Inhalation Exposure Estimates
EPA did not identify inhalation monitoring data to assess exposures during use of fertilizers containing
formaldehyde in outdoors including lawns. Therefore, EPA estimated inhalation exposures using Monte
Carlo simulation of models based on the OES. EPA assumed that the formaldehyde-containing product
arrives at the site in its final formulation and is used with no engineering controls present. Actual
exposures may differ based on worker activities, formaldehyde throughputs, and facility processes.
EPA modeled two scenarios for the use of fertilizer—agricultural and lawn and landscape applications.
The Agency assumes that agricultural applications may encompass larger land areas with less frequent
applications for the worker per year. For lawn and landscape professionals, application areas may vary
from small residential lawns to large commercial fields such as golf courses with more frequent
applications. For both scenarios, EPA applied the EPA/OPPT Mass Balance Inhalation Model for
container unloading and cleaning of equipment That model estimates the amount of chemical inhaled by
a worker during a vapor-generating activity. EPA estimated the inhalation exposure for the exposure
points using a vapor generation rate (G) and exposure duration based on the ChemSTEER User Guide
for the EPA/OPPT Mass Balance Inhalation Model ( ) and Chemical Engineering
Branch Manual for the Preparation of Engineering Assessments, Volume 1 ( ). EPA
calculated vapor generation rates for the exposure points with possible vapor generation rate models and
default values presented in the aforementioned reports. The Monte Carlo simulation varies the following
parameters: ventilation rate, mixing factor, saturation factor, working years, formaldehyde mass fraction
in the urea-formaldehyde product, hours exposed for exposure point B, and production volume.
Selection of the distributions used to assess these parameters is detailed in Section C.6. For application,
EPA/OPPT does not have a model to estimate the vapor-generation from the spray application for this
use.
The Agency used the vapor generation rate, exposure duration parameters, and the EPA Mass Balance
Inhalation Model to determine a TWA exposure for each exposure point. EPA assumed the same worker
performed each activity throughout their work shift and estimated the 8-hour TWA by combining the
exposures from each exposure point and averaging over 8 hours within the Monte Carlo simulation.
EPA assumed workers had no exposure outside each exposure activity.
For dry granulated fertilizer and certain spray applications, a worker may inhale particulate or mist
containing formaldehyde. EPA used the OSHA PNOR limiting model for the industry group of
Agriculture, Forestry, Fishing and Hunting to model this exposure. With the model, exposures are
estimated as an 8-hour TWA. Table 3-52 summarizes the estimated full shift TWA exposures for use of
fertilizer containing formaldehyde. The high-end values represent the 95th percentile and the central
tendency values represent the 50th percentile of the simulation outputs.
Table 3-52. Summary of Inhalation Exposure Modeling Data for the Use of Fertilizers Containing
Formaldehyde in Outdoors Including Lawns
Exposure Concentration Type
Central Tendency
(ppm)
High-End
(ppm)
Data Quality Rating of Air
Concentration Data
Aijnculluiv scenario (\;i|nn'yiis)
Inhalation exposure during
container unloading
0.03
0.13
N/A - Modeled data
Equipment cleaning exposure
0.04
0.17
N/A - Modeled data
8-hour TWA (total exposure)
0.034
0.145
N/A - Modeled data
l.iuulsc;i|v uses (wipur Lias)
Page 112 of 313
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Exposure Concentration Type
Central Tendency
(ppm)
High-End
(ppm)
Data Quality Rating of Air
Concentration Data
Inhalation exposure during
container unloading
0.013
0.07
N/A - Modeled data
Equipment cleaning exposure
0.042
0.17
8-hour TWA (total exposure)
()02
0.08
Application olTcilili/.cr (\lisl or Parlicukilc)
Unloading, application,
equipment cleaning
n (in23
0.0122
\ A Modeled data
3.24.1.4 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The maximum concentration assessed for this
OES was 1 percent based on reporting data for the agricultural non-pesticidal products in the 2020 CDR
( 2020a). One submitter reported 30 to 60 percent and the other reported less than 1 percent
for the agricultural non-pesticidal products. The high concentration reported may refer to the
intermediate product sold as urea formaldehyde concentrate (UFC), which contains 60 percent
formaldehyde. This product is then used in the production of solid urea and ureaform fertilizers (
). The minimum concentration identified was 0.1 percent based on formaldehyde report data
from the Tennessee Valley Authority (TVA) ( ). The calculated occupational dermal
exposures for this OES are 14 |ig/cm2 as the central tendency value and 21 |ig/cm2 as the high-end
value.
3.25 Commercial Use - Chemical Substances in Outdoor Use Products -
Explosive Materials
3.25.1 Use of Explosive Materials
3.25.1.1 Process Description
Formaldehyde is emitted in explosive materials such as ground-level pyrotechnics and firearms
("Quemerais. .za) I j i oiCciii ct dL ^01 u). Information from the 2020 CDR indicates that formaldehyde is
used as a chemical ingredient for propellant composition, although the concentrations are unknown
( 2020a). In an occupational setting, EPA expects explosive materials to be used when a
worker conducts outdoor pyrotechnic performances or in commercial or military firing ranges. The
Agency did not identify container-specific information on formaldehyde in explosive materials;
however, the Agency expects products to arrive in packages of assorted sizes. The explosive material is
ignited, undergoes a combustion reaction, and explodes ("Croteau et at.. 2010).
3.25.1.2 Worker Activities
Workers are potentially exposed to formaldehyde during loading/unloading of explosives containing
formaldehyde, use of the explosive material and possibly through cleaning of equipment. EPA did not
identify any information to indicate the extent of use of PPE by the workers in processes using
formaldehyde in explosive materials.
ONUs include employees (e.g., supervisors, managers) at explosive materials sites who do not directly
handle formaldehyde. Therefore, the ONUs are expected to have lower inhalation exposures, lower
vapor-through-skin uptake, and no expected dermal exposure.
Page 113 of 313
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3.25.1.3 Inhalation Exposure Estimates
The information and data quality valuation to assess occupational exposures during use of explosive
materials is listed in Table 3-53 and described in detail below. Table 3-54 summarizes the monitoring
data for use of explosive materials containing formaldehyde.
Table 3-53. Use of Explosive Materials Inhalation Exposure Data Evaluation
Worker Activity or
Sampling Location
Data Type
Number of
Samples
Overall Data Quality
Determination
Source
Unknown
PBZ monitoring data
18
Medium
(OSHA. 2019)
Performer
PBZ monitoring data
1
High
(Croteau et al., 2010)
The other short-term sample was taken at a firework show (Croteau et at.. 2010). All personal and area
samples provided through Croteau; were at or below the LOD of 0.016 ppm (Croteau et at.. 2010). The
only 8-hour TWA PBZ samples available were from OSHA's CEHD. OSHA sampled military and air
force bases as well as companies within the fabricated metal production manufacturing sector. The
methodology for obtaining and analyzing this data is described in Section 2.5.1.
Fifty percent of 15-minute exposure samples, 48 percent of greater than 15-minute to less than 330-
minute, and 55 percent of greater than 14-minute to less than 60-minute were measured below the LOD.
To estimate exposure concentrations for this data, EPA followed the Guidelines for Statistical Analysis
of Occupational Exposure Data (U. 4a), as discussed in Section 2.5.1.
Data is not available to estimate ONU exposures; EPA estimates that ONU exposures are lower than
worker exposures since ONUs do not typically directly handle chemicals. In lieu of ONU-specific data,
EPA uses worker central tendency exposure results as a surrogate to estimate exposures for ONUs.
The high-end and central tendency values for the data represent the 95th and 50th percentile,
respectively. The calculated values are summarized in Table 3-54.
Table 3-54. Summary of Inhalation Exposure Monitoring Data for the Use of Explosive Materials
Exposure
Concentration
Type
Worker Exposures
Number
of
Worker
Samples
ONU
Exposures
Number
of ONU
Samples
Data Quality
Rating of Air
Concentration
Data
Central
Tendency
(ppm)
High-
End
(ppm)
Full shift
8-hour TWA
0.04
0.06
5
0.04
N/A
Medium
Short-term
15-minute
0.09
0.26
10
EPA did not identify
short-term data for
ONUs
Medium
>15 to <330
minutes
0.09
0.17
29
Medium
>14 to <60
minutes
0.10
0.18
27
Medium
3.25.1.4 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The maximum concentration assessed for this
OES was 1 percent. Explosive materials were not reported in 2020 CDR ( 20a) and were
reported by one submitter at less than 1 percent concentration in the 2016 CDR. EPA did not identify
additional concentration information on explosive materials. The calculated occupational dermal
Page 114 of 313
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exposures for this OES are 14 |ig/cm2 as the central tendency value and 21 |ig/cm2 as the high-end
value.
3.26 Commercial Use - Chemical Substances in Packaging, Paper, Plastic,
Hobby Products - Paper Products; Plastic and Rubber Products; Toys,
Playground, and Sporting Equipment
3.26.1 Use of Packaging, Paper, Plastics, and Hobby Products
3.26.1.1 Process Description
A public comment submitted by ACC indicates the use of formaldehyde in paper products ("ACC. ^ ).
Urea and melamine resins, containing up to 1.5 percent free formaldehyde, are used in paper treating
and coating (NICNAS. 2006). In the 2020 CDR, one facility reported 5 percent of its PV for
downstream use of formaldehyde in paper articles with a maximum concentration of 1 to less than 30
percent ( 2020a). Packaging and other hobby products were not in the 2020 CDR.
Formaldehyde has been identified in carbonless copy paper (CCP) which may be used in office settings,
educational supply stores, and printing shops (NIOSH. 2000; Zimmer and Hadwen. 1993; NIOSH.
1984b). Sources indicate concentrations of formaldehyde in CCP ranging from 33 .6 to 800,000 |ig/kg
(Chrostek. 1985; NIOSH rsVH>, ockel et ai. 1981). EPA did not find container-specific information
on formaldehyde in CCP; however, EPA expects paper products to arrive ready for use in large boxes
containing various amounts of paper. Workers may use CCP for several activities, such as writing,
copying, archiving records, and sorting. According to one NIOSH report, the spent paper is either filed
away for future use or disposed of landfill or recycling (NIOSH. 2000). In general, site trash could be
collected for disposal as solid wastes that are recycled, incinerated, or landfilled. EPA did not identify
process-specific information for formaldehyde in packaging or other hobby products.
3.26.1.2 Worker Activities
Workers may potentially be exposed to formaldehyde during use of packaging, paper, and hobby
products during handling of packaging, paper, or other similar products. EPA identified one literature
source describing ventilation as the only engineering control in place (Hall et ai. 2002). The Agency did
not identify the extent of use of PPE by the workers at sites with use of packaging, paper, and hobby
products.
ONUs include employees (e.g., supervisors, managers) at use of packaging, paper, and hobby product
sites who do not directly handle formaldehyde. Therefore, the ONUs are expected to have lower
inhalation exposures, lower vapor-through-skin uptake, and no expected dermal exposure.
3.26.1.3 Inhalation Exposure Estimates
The information and data quality valuation to assess occupational exposures during use of packaging,
paper, and hobby products is listed in Table 3-55 and described in detail below. Table 3-56 summarizes
the 8-hour TWA and short-term monitoring data for use of packaging, paper, and hobby products
containing formaldehyde.
Table 3-55. Use of Packaging, Paper, and Ho
)by Products
nhalation Exposure Data Evaluation
Worker Activity or
Sampling Location
Data Type
Number of
Samples
Overall Data Quality
Determination
Source
Unknown
PBZ monitoring data
4
Medium
(OSHA. 2019)
Page 115 of 313
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All samples used were from OSHA's CEHD. OSHA sampled companies within the retail trade and
transportation and warehousing sectors. The 15-minute data were from OSHA sampling of a mail
delivery service. The methodology for obtaining and analyzing this data is described in Section 2.5.1.
It should be noted that one of the two 15-minute data and one of the four greater than 15-minute to less
than 330-minute samples measured below the LOD. To estimate exposure concentrations for these data,
EPA followed the Guidelines for Statistical Analysis of Occupational Exposure Data (
1994a). as discussed in Section 2.5.1.
Data is not available to estimate ONU exposures; EPA estimates that ONU exposures are lower than
worker exposures since ONUs do not typically directly handle chemicals. In lieu of ONU-specific data,
EPA uses worker central tendency exposure results as a surrogate to estimate exposures for ONUs.
The high-end and central tendency values for the data represent the maximum and 50th percentile,
respectively. The calculated values are summarized in Table 3-56.
Table 3-56. Summary of Inhalation Exposure Monitoring Data for the Use of Packaging, Paper,
and Hobby Products
Exposure
Concentration
Type
Worker Exposures
Number of
Worker
Samples
ONU
Exposures
Number of
ONU Samples
Data Quality
Rating of Air
Concentration Data
Central
Tendency
(ppm)
High-End
(ppm)
8-hour TWA
0.015
0.02
2
0.02
N/A
Medium
15-minute
0.23
0.28
2
EPA did not identify 15-minute
data for ONUs
Medium
>15 to <330
minutes
0.01
0.03
4
EPA did not identify short-term
data for ONUs
High
Hall (2002) took area samples for formaldehyde across 11 different governmental office buildings. The
study measured the formaldehyde concentration in areas where mail was handled, other indoor air areas,
and outside. For areas where mail was handled the formaldehyde concentration ranged from 5 to 15 ppb,
above the outdoor formaldehyde concentrations (trace to 4 ppb). However, similar formaldehyde
concentrations were seen in other indoor air areas, where no mail was handled.
3.26.1.4 Dermal Exposure Estimates
The maximum concentration identified for this OES was 1 to 30 percent, based on reporting data for the
other articles with routine direct contact during normal use, including paper articles in the 2020 CDR
( 2020a). Other sources indicate the percentage of formaldehyde in paper products at below 1
percent fChrosti 5; NIOSH. 1984b; Gockel et at.. 1981). Because paper products are solid articles,
EPA did not estimate dermal exposure using the dermal loading calculation as loading values are based
on liquid loading. The Agency notes that dermal exposure to formaldehyde may still be possible but it is
not quantified.
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3.27 Commercial Use - Chemical Substances in Packaging, Paper, Plastic,
and Hobby Products - Arts, Crafts, and Hobby Materials
3,27.1 Use of Craft Materials
3.27.1.1 Process Description
An SDS identified formaldehyde in craft consumer glue in concentrations less than 0.1 percent (
20b; Elmer's. 2012). According to the 2020 CDR, one manufacturer/importer reported
downstream use of formaldehyde as an intermediate in solvent-based paint with a concentration ranging
from 30 to 60 percent (U.S. EPA. 2020a). EPA did not identify process-specific information for
formaldehyde in paints, coatings, and adhesives marketed as craft and hobby materials for commercial
use. The formaldehyde use report indicated up to 10 percent in consumer craft materials, EPA assumes
that commercial users may be using these consumer products. The Agency expects paints, coatings, and
adhesives marketed as craft and hobby products to be used in its final formulation and to be applied
manually by brush, roller, or spray onto the substrate. Following application, EPA expects the substrate
to be allowed to cure or dry before use.
3.27.1.2 Worker Activities
Workers are potentially exposed to formaldehyde during the use of craft materials during
loading/unloading of craft materials containing formaldehyde as well as the cleaning of equipment
which use craft materials containing formaldehyde. EPA did not identify any information to indicate the
extent of use of PPE by the workers in processes using formaldehyde in craft materials.
ONUs include employees (e.g., supervisors, managers) at craft materials sites who do not directly handle
formaldehyde. Therefore, the ONUs are expected to have lower inhalation exposures, lower vapor-
through-skin uptake, and no expected dermal exposure.
3.27.1.3 Inhalation Exposure Estimates
EPA did not identify monitoring data or a NAICS code specific to commercial uses of arts and crafts
products. The Agency assumes that these products are paints, coatings, and adhesives; therefore,
monitoring data considered in the use of paints, coatings, and adhesives was considered.
EPA expects arts and craft products would be applied manually by brush, roller, or spray applications.
The exposure estimates for non-spray application were not used because they include application
methods not expected with arts and craft products (e.g., curtain and dip painting). EPA used the
exposure estimates for spray or unknown applications as surrogate monitoring data.
3.27.1.4 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The concentration assessed for this OES was
10 percent based on the formaldehyde use report. Note that concentrations can be as low as 0.1 percent
as reported by the AC A via public comment (AC A. ). As these products may include spray
products, high-end dermal exposures are calculated based on a higher amount of formaldehyde
remaining on skin upon immersion (10.3 mg/cm2 per event), and the central tendencies are based on a
lower amount of formaldehyde remaining on skin upon immersion (3.8 mg/cm2 per event). The
calculated occupational dermal exposures for this OES are 380 |ig/cm2 as the central tendency value and
1,030 |ig/cm2 as the high-end value.
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3.28 Commercial Use - Chemical Substances in Packaging, Paper, Plastic,
Hobby Products - Ink, Toner, and Colorant Products; Photographic
Supplies
For Commercial use - chemical substances in packaging, paper, plastics, and hobby products - ink,
toner, and colorant products, EPA assessed two OESs:
• Use of printing ink, toner, and colorant products containing formaldehyde; and
• Photo processing using formulations containing formaldehyde.
3,28.1 Use of Printing Ink, Toner, and Colorant Products Containing Formaldehyde
COU: Commercial uses - chemical substances in packaging, paper, plastic, hobby products - ink, toner,
and colorant products; photographic supplies.
3.28.1.1 Process Description
Formaldehyde is a component of printing inks, which may include letterpress, offset, lithographic,
inkjet, and flexographic inks (I v < < \ 2020b. JO 10; Tuomi et at.. 2000). The inks may be used for
newspapers, books, labeling, and packaging. Printing activities may be categorized by the following
processes: lithography, gravure, flexography, letterpress, digital, and screen-printing, with lithography
being the most used (U.S. EPA. 2010).
EPA identified one source that indicated formaldehyde contained in ink used for printing labels onto
aluminum cans (Rodriguez et at.. ). There are many different printing processes. Inks typically
arrive at the facility in large drums and may be pumped into smaller containers for storage (
2002). The formulation may require mixing before loading into the printing machine (1 c< « V \ AW).
The printing process may be web-fed, in which a continuous roll of paper is fed through the machine, or
sheet-fed, in which printing occurs on individual pieces of paper or substrate ( ). In the
case of web-fed, the paper must be cut to size after printing. Most commercial printing processes are
sheet-fed while newspapers, magazines, and books are web-fed. The printing press is cleaned either at
the end of the working day or when the plates are changed. See Figure 3-7 for typical release and
exposure points during the use of printing inks ( ).
During lithography, the ink is unloaded from a container to an ink tank on the printing machine (
). The ink is transferred to the ink rollers, then to the printing cylinder, then to the
intermediate blanket roll, and finally to the paper. Lithography processes may be sheet-fed, non-heat-set-
fed, or heat-set-fed. Web-fed lithography may be used in the production of periodicals, newspapers, and
books ( 10). After printing and coating, the ink is dried via gas-fired ovens at 350 °F (Cook
and Paee. 2000). Press equipment is routinely cleaned during printing operations with blanket wash
solutions and wetting agents. Some machines are manually cleaned using shop rags, while other
machines have auto-blanket wash systems (Cook and Paee. 2000).
Gravure printing is a process in which an image is etched with millions of minute cells below the surface
of a plate or cylinder. Gravure is typically used for currency. Ink flows from the cells to the substrate at
high speeds. As the substrate passes through air dryers, the ink dries through evaporation. Gravure is
generally used for long printing jobs where engraving new images is not frequently required (
2010).
Flexography is a type of relief printing in which the image area is raised relative to the non-image area
(l c> < ^ \ 1010). Flexographic printing may be sheet-fed or web-fed, and is typically used for flexible
and rigid packaging, newspapers, magazines, and consumer paper products (\ v < < \ JO 10). The three
Page 118 of 313
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primary flexographic ink systems are solvent-based, water-based, and UV-cured inks. Solvent-based and
water-based inks dry via evaporation, while UV-cured inks are cured by chemical reactions (U.S. EPA.
2002). The liquid ink typically arrives at the facility in 55-gallon drums and is pumped into a dispensing
system or poured into 5-gallon cans (U.S. EPA. 1999). The ink is poured into an enclosed ink sump
where it is pumped to an enclosed chamber. The substrate is run through the press, and the unused ink is
pumped back out of the chamber into the sump.
Letterpress printing uses a relief plate or cylinder with a raised metal image (U.S. EPA. 2010). Sheet-
fed, heat-set web and non-heat-set web pressed may be used. Letterpress is typically used to print
newspapers, magazines, books, stationary, and advertising; however, it is difficult to print high-quality
shaded images using this process. Digital printing encompasses any printing that may be completed via
digital files and can incorporate data directly for compact database and printing to a digital press not
using traditional methods of film or printing plates (U.S. EPA. 2010). During screen printing, ink is
transferred to the substrate through a porous screen marked with a stencil. Both sheet-fed and web-fed
processes may be used. The substrate can either be dried after each color application or after all colors
have been printed. Screen printing is typically used for signs, electronics, displays, decals, and textiles
(U.S. EPA. 2010; NIOSH. 1981b).
Printing Press
4), (5), (C), (D)
Dryer
Occupational Exposure:
A. Dermal exposure to ink and inhalation exposure to volatilized formaldehyde during unloading
B. Inhalation exposure to fugitive air releases from ink reservoir
C. Inhalation exposure to ink mist generated from printing press
D. Dermal and inhalation exposure to formaldehyde during equipment cleaning
E. Inhalation exposure to fugitive air releases from drying
Figure 3-7. Typical Release and Exposure Points During the Use of Formaldehyde in Printing Inks
(U.S. EPA. 2010)
3.28.1.2 Worker Activities
Workers are potentially exposed to formaldehyde during the use of printing ink, toner, and colorant
products containing formaldehyde during loading/unloading activities, equipment cleaning, and spray
activities (Rodriguez et al.. 2012). EPA did not identify any information to indicate the extent of use of
PPE by the workers in processes using formaldehyde in ink, toner, and colorant products.
Page 119 of 313
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ONUs include employees (e.g., supervisors, managers) at printing sites who do not directly handle
formaldehyde. Therefore, the ONUs are expected to have lower inhalation exposures, lower vapor-
through-skin uptake, and no expected dermal exposure.
3.28.1.3 Inhalation Exposure Estimates
The information and data quality valuation to assess occupational exposures during photo processing
using formulations containing formaldehyde is listed in Table 3-57 and described in detail below. Table
3-58 summarizes the monitoring data for use of printing ink, toner, and colorant products containing
formaldehyde.
Table 3-57. Use of Printing Ink, Toner, and Colorant Products Inhalation Exposure Data
Evaluation
Worker Activity or Sampling
Location
Data Type
Number of
Samples
Overall Data
Quality
Determination
Source
Unknown
PBZ monitoring data
48
Medium
(OSHA. 2019)
Front end, printer, chemical
process operator, millwright,
forklift operator, lacquer spray
PBZ monitoring data
21
High
(Rodriguez et aL
2012)
Operating a color press
PBZ monitoring data
12
High
( k and Page. 2000)
Rodriguez sampled at aluminum beverage can manufacturing plants in the United States. The study
sampled various workers and locations for formaldehyde over 2 days as it was used as a component of
printing ink for the printing press equipment. Cook conducted a similar study and sampled color press
operators. OSHA sampled companies within the commercial printing sectors. The methodology for
obtaining and analyzing this data is described in Section 2.5.1.
It should be noted that 81 percent of the 15-minute data samples and 80 percent of less than 60 minutes
measured below the LOD, and therefore these estimates are highly biased. For samples measured
beyond 15 minutes and up to 330 minutes, 23 percent of samples measured below the LOD. To estimate
exposure concentrations for that data, EPA followed the Guidelines for Statistical Analysis of
Occupational Exposure Data (U. 4a), as discussed in Section 2.5.1.
Data is not available to estimate ONU exposures; EPA estimates that ONU exposures are lower than
worker exposures since ONUs do not typically directly handle chemicals. In lieu of ONU-specific data,
EPA uses worker central tendency exposure results as a surrogate to estimate exposures for ONUs for 8-
hour TWA.
The high-end and central tendency values for the 8-hour TWA data represent the 95th and 50th
percentile, respectively. The calculated values are summarized in Table 3-58.
Page 120 of 313
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Table 3-58. Summary of Inhalation Exposure Monitoring Data for the Use of Printing Ink, Toner,
Exposure
Concentration
Type
Worker Exposures
Number
of
Worker
Samples
ONU
Exposures
Number of
ONU
Samples
Data Quality
Rating of Air
Concentration
Data
Central
Tendency
(ppm)
High-
End
(ppm)
Full shift
8-hour TWA
0.04
0.13
41
0.04
N/A
Medium to High
Short-term
15-minute
0.11
0.22
11
EPA did not identify
short-term data for ONUs
Medium
>15 to <330
minutes
0.06
0.28
30
EPA did not identify
short-term data for ONUs
Medium
>14 to <60
minutes
0.11
0.34
15
EPA did not identify
short-term data for ONUs
Medium
3.28.1.4 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The maximum concentration assessed was 2
percent based on data from the 2006 formaldehyde report from the NICNAS (NICNAS. 2006). The
calculated occupational dermal exposures for this OES are 28 |ig/cm2 as the central tendency value and
42 |ig/cm2 as the high-end value.
3.28.2 Photo Processing Using Formulations Containing Formaldehyde
3.28.2.1 Process Description
Formaldehyde has been identified as a component in photographic film processing (Eastman Kodak.
2009; NICNAS. 2006; NIOSH. 1982a. 1974a). Formaldehyde is used as a preservative, stabilizer,
replenisher, and hardener in final baths to prevent deterioration of image quality and damage to film
coatings (NICNAS. 2006). An SDS indicates formaldehyde is present in photographic processing with
weight fractions ranging from 5 to 15 percent (Eastman Kodak. 2009). This condition of use was not
reported in the 2016 or 2020 CDR.
According to NICNAS, commercial film processing sites typically use enclosed machines with a final
bath tank specifically for formaldehyde solutions (NICNAS. 2006). EPA did not identify specific
container information on formaldehyde used in film processing. The formaldehyde is received, poured
into the final bath tank, and diluted with water to achieve a concentration ranging from 0.1 to 15 percent.
The final bath is replenished one to two times per week (NICNAS. 2006). This process may be
automated or manual. For manual operations, the diluted solution is poured into a tray in a dark room
where negative or film paper is submerged to develop (NICNAS. 2006).
During specialized film processing, such as aerial film processing, formaldehyde is used in
concentrations ranging from 20 to 35 percent (NICNAS. 2006). Formaldehyde solutions are received in
9-L or 19-L plastic drums. A tube is inserted into the drum and the solution is pumped into an enclosed
final bath and diluted to 1 percent in a film processing machine (NICNAS. 2006).
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Film development is typically done via a batch process (NUCHAS. 2006). The final product is
transferred to containers and dispatched to customers. The concentration of formaldehyde in the end
product is typically 10.4 percent (NICNAS. 2006).
3.28.2.2 Worker Activities
Workers are potentially exposed to formaldehyde during photo processing during photo development
activities, printing, loading/unloading activities, and equipment cleaning (Salisbury. 1996). Possible
engineering controls utilized by photo processing sites include general ventilation such as HVAC units
(Salisbui 5).
ONUs include employees (e.g., supervisors, managers) at photo processing sites who do not directly
handle formaldehyde. Therefore, the ONUs are expected to have lower inhalation exposures, lower
vapor-through-skin uptake, and no expected dermal exposure.
3.28.2.3 Inhalation Exposure Estimates
The information and data quality evaluation to assess occupational exposures during photo processing
using formulations containing formaldehyde is summarized in Table 3-59 and described in detail below.
The monitoring data for photo processing using formulations containing formaldehyde are summarized
in Table 3-60.
Table 3-59. Photo Processing Using Formulations Containing Formaldehyde Inhalation Exposure
Data Evaluation
Worker Activity or
Sampling Location
Data Type
Number of
Samples
Overall Data Quality
Determination
Source
Unknown
PBZ monitoring data
18
Medium
(OSHA. 2019)
All samples available came directly from OSHA's CEHD. OSHA sampled eight companies within the
Photofinishing Laboratories (except One-Hour) and Photography Studios, Portrait sectors. The
methodology for obtaining and analyzing this data is described in Section 2.5.1.
It should be noted that 20 percent of the 15-minute to 330-minute data samples, 60 percent of the 14-
minute to 60-minute data samples, and 75 percent of the 15-minute data samples were measured below
the LOD. To estimate exposure concentrations for these data, EPA followed the Guidelines for
Statistical Analysis of Occupational Exposure Data (U.S. EPA. 1994a). as discussed in Section 2.5.1.
Data is not available to estimate ONU exposures; EPA estimates that ONU exposures are lower than
worker exposures since ONUs do not typically directly handle chemicals. In lieu of ONU-specific data,
EPA uses worker central tendency exposure results as a surrogate to estimate 8-hour TWA exposures for
ONUs.
The high-end and central tendency values represent the 95th and 50th percentile, respectively. The
calculated values are summarized in Table 3-60.
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Table 3-60. Photo Processing Using Formulations Containing Formaldehyde
Exposure
Concentration
Type
Worker Exposures
Number
of
Worker
Samples
ONU
Exposures
Number of
ONU
Samples
Data Quality
Rating of Air
Concentration
Data
Central
Tendency
(ppm)
High-
End
(ppm)
Full shift
8-hour TWA
0.03
0.04
4
0.03
N/A
Medium
Short-term
15-minute
0.06
0.06
4
EPA did not identify
short-term data for ONUs
Medium
>15 to <330
minutes
0.03
0.09
10
EPA did not identify
short-term data for ONUs
Medium
>14 to <60
minutes
0.05
0.05
5
EPA did not identify
short-term data for ONUs
Medium
3.28.2.4 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The maximum concentration assessed for this
OES was 35 percent, based on data from the 2006 formaldehyde report from the NICNAS (NICNAS,
2006). The calculated occupational dermal exposures for this OES are 490 |ig/cm2 as the central
tendency value and 735 |ig/cm2 as the high-end value.
3.29 Commercial Use - Chemical Substances in Products Not Described by
Other Codes - Laboratory Chemicals
3.29.1 General Laboratory Use
3.29.1.1 Process Description
Formaldehyde may be used as a fixative in forensic/hospital mortuaries, pathology laboratories, other
medical-related laboratories, and aerospace-related laboratories (Bruno et at.. 2018; NICNAS. 2006).
Formaldehyde used in laboratories is often a neutral buffered formalin which can contain up to a range
of 2.5 to 50 percent percent formaldehyde, with a mode of less than 20 percent. ( mo et at.. 2018; Xu
and Stevuh A\l_6; Sancini etai. i^t L ' >-'\as am! ^iista. 2010; NICNAS. 2006; Ro\ I )). EPA
expects labs likely purchase at higher concentrations and dilute to the desired concentrations for specific
applications. These dilutions can be automated using enclosed mixing systems or manually completed
by the lab worker (NICNAS. 2006).
Gross dissection and examination of the tissue typically take place in pathology or other medical
laboratories after the specimen has been in full contact with a formalin solution containing 3.7 percent
formaldehyde for several hours or longer (Xu and Stewjn , •• 'SH. 1983a). The tissue is placed
into plastic cassettes and the cassettes are immersed in trays of formalin during grossing (Xu and
Stew ). The cassettes are processed into paraffin blocks, sliced extremely thin, and mounted on a
slide (Xu and Stewart. 2016; Kilburn et at.. 1985; NIOS 2b). The slide goes through a series of
solutions where stains are applied, and the slides are fixed (NIOSH. 1982b). A pathologist examines the
slide via microscopic analysis (Xu and Stewart. 2016; NIOSH. 1982b). One source indicates that
specimens no longer needed are disposed of once a week. The specimen is rinsed with water and the
formaldehyde is washed down the sink (NIOSH. 1982b). Loading tissue cassettes and tissue processing
typically takes 1.5 hours and may occur up to several times a week (NIOS ).
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Formaldehyde may also have uses in laboratories as an analytical standard for various applications.
Figure 3-8 illustrates a typical process for the use of laboratory chemicals primarily used as analytical
standards, as well as the relevant environmental release and occupational exposure points (U.S. EPA.
2023d)-
1 )(^P)( 3 )| 4
Occupational Exposures:
a) Full shift inhalation and dermal exposure from all activities.
b) Inhalation and dermal exposure from unloading formaldehyde from transport containers (if full shift estimates are
not used).
c) Inhalation and dermal exposure to formaldehyde during container cleaning throughout sample preparation and
testing activities (if full shift estimates are not used).
d) Inhalation exposure to volatilized formaldehyde and dermal exposure to solids and liquids during equipment
cleaning (if full shift estimates are not used).
e) Inhalation exposure to volatilized formaldehyde and dermal exposure to solids and liquids during laboratory
analyses (if full shift estimates are not used).
f) Dermal exposure during disposal of formaldehyde (if full shift estimates are not used).
Figure 3-8. Typical Exposure Points During the Use of Formaldehyde in Laboratory Chemicals
(U.S. EPA. 2023d)
3.29.1.2 Worker Activities
Workers are potentially exposed to formaldehyde during general laboratory use for activities within the
laboratory, unloading transport containers, container and equipment cleaning, sample preparation and
testing, laboratory analyses, and disposal ( )23d). EPA identified one source describing
mechanical ventilation as the only engineering control set in place (Ho et at.. ). The Agency did not
identify the extent of use of PPE by the workers in laboratories.
ONUs include employees (e.g., supervisors, managers) at laboratory sites who do not directly handle
formaldehyde. Therefore, the ONUs are expected to have lower inhalation exposures, lower vapor-
through-skin uptake, and no expected dermal exposure.
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3.29.1.3 Inhalation Exposure Estimates
The information and data quality valuation to assess occupational exposures during general laboratory
use is listed in Table 3-61 and described in detail below. Table 3-62 summarizes the monitoring data for
general laboratory use.
Table 3-61. General Laboratory Use Inhalation Exposure I
>ata Evaluation
Worker Activity or
Sampling Location
Data Type
Number of
Samples
Overall Data Quality
Determination
Source
Unknown
PBZ monitoring data
882
Medium
(OSHA. 2019)
Surveillance Necropsy
PBZ monitoring data
1
Medium
("Diberardinis et
ah, 2001)
Lab Personnel
PBZ monitoring data
1
Medium
(Diberardinis et
ah.2001)
Pathologist, Forensic
Assistant
PBZ monitoring data
10
High
(NIOSH. 2013)
Short-term samples had data available from three data sources; however, 1 source did not describe
engineering controls or the activities of the worker during the sampling (Diberardinis et at.. 2001). The
other reported that air from the laboratory was exhausted outdoors. (NIO| ). The remaining data
is from OSHA CEHD. All but one of thl5-minute samples were from OSHA's CEHD; the other had no
engineering controls or worker activities to report (Diberardinis et at.. 2001). All of the 8-hour TWA
samples were from OSHA's CEHD. OSHA sampled the following sectors: professional, scientific, and
technical services, educational services, veterinary care, health care and social assistance. The
methodology for obtaining and analyzing this data is described in Section 2.5.1.
Data is not available to estimate ONU exposures; EPA estimates that ONU exposures are lower than
worker exposures since ONUs do not typically directly handle chemicals. In lieu of ONU-specific data,
EPA uses worker central tendency exposure results as a surrogate to estimate exposures for ONUs.
It should be noted that 14 percent of the 8-hour TWA samples, 27 percent of greater than 15-minute to
less than 330-minute, 34 percent of 15-minute samples, and 34 percent of greater than 14-minute to less
than 60-minute samples measured below the LOD. To estimate exposure concentrations for these data,
EPA followed the Guidelines for Statistical Analysis of Occupational Exposure Data (
1994a). as discussed in Section 2.5.1.
The high-end and central tendency values for the data represent the 95th and 50th percentile,
respectively. The calculated values are summarized in Table 3-62.
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Table 3-62. Summary of Inhalation Exposure Monitoring Data for General Laboratory Use
Exposure
Concentration
Type
Worker Exposures
Number of
Worker
Samples
ONU
Exposures
Number of
ONU
Samples
Data Quality
Rating of Air
Concentration
Data
Central
Tendency
(ppm)
High-
End
(ppm)
Full shift
8-hour TWA
0.09
0.55
139
0.09
N/A
Medium
Short-term
15-minute
0.25
2.13
283
EPA did not identify
short-term data for ONUs
Medium
>15 to <330
minutes
0.12
0.94
454
EPA did not identify
short-term data for ONUs
Medium
>14 to <60
minutes
0.24
2.15
369
EPA did not identify
short-term data for ONUs
Medium
In addition, EPA identified additional monitoring studies that provided summary statistics, which are
provided in the Supplemental Formaldehyde Occupational Monitoring Data Summary. One study
measured full shift exposures to workers in various laboratories in a cancer research institute (Pala et al.,
2008). Viegas (2009) measured full-shift exposures for pathologists in Portugal with a range of 0.02 to
0.51 ppm. The exposures ranged from 0.004 ppm to 0.22 ppm (n = 36). Another study measured full
shift PBZ exposures to workers in hospital pathology laboratories in Portugal, and this resulted in an
arithmetic mean of 0.38 ppm (Costa et al.. 2015). In addition, the study measured short-term exposures,
which ranged from 0.3 to 3.2 ppm. The short-term tasks included examination of formaldehyde-
preserved specimens, and disposal of specimens and waste solutions.
For laboratory uses outside of fixative purposes, EPA identified workers in a quality control lab in
Australia for a facility that manufactures formaldehyde-based resin at 0.2 ppm, which is within the range
of EPA's estimate for the scenario. Of note, lab use that occurs within a facility may be captured within
the exposure scenario of the facility. For example, monitoring data occurring at lab at a formaldehyde
manufacturer may be covered in the Manufacturing OES.
3.29.1.4 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models. The maximum concentration assessed for this OES was 50 percent based
on the known concentration of formaldehyde in solution used in laboratories. The calculated
occupational dermal exposures for this OES are 700 |ig/cm2 as the central tendency value and 1050
|ig/cm2 as the high-end value.
3.30 Disposal
3.30.1 Worker Handling of Wastes
3.30.1.1 Process Description
Each of the COUs of formaldehyde may generate waste streams of the chemical that are collected and
transported to third-party sites for disposal or treatment. Industrial sites that treat or dispose of onsite
wastes that they generate are assessed in each condition of use assessment in Sections 3.1 through 3.30.
Wastes of formaldehyde that are generated during a condition of use and sent to a third-party site for
disposal, including treatment or final disposition (e.g., landfilling, incineration, underground injection)
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may include the following:
• Wastewater: Formaldehyde may be contained in wastewater discharged to POTW or other, non-
public treatment works for treatment. Industrial wastewater containing formaldehyde discharged
to a POTW may be subject to EPA or authorized NPDES state pretreatment programs. The
assessment of workers at on-site wastewater treatment facility of formaldehyde is considered
within its respective OES.
• Solid Wastes: Solid wastes are defined under RCRA as any material that is discarded by being:
abandoned; inherently waste-like; a discarded military munition; or recycled in certain ways
(certain instances of the generation and legitimate reclamation of secondary materi als are
exempted as solid wastes under RCRA). Solid wastes may subsequently meet RCRA's definition
of hazardous waste by either being listed as waste at 40 CFR 261.30 to 261.35 or by meeting
waste-like characteristics as defined at 40 CFR 261.20 to 261.24. Solid wastes that are hazardous
are regulated under the more stringent requirements of Subtitle C of RCRA, whereas non-
hazardous solid wastes are regulated under the less stringent requirements of Subtitle D of
RCRA. Formaldehyde is a "U-listed" hazardous waste under code U122 under RCRA; therefore,
discarded, unused pure, and commercial grades of formaldehyde are regulated as hazardous
waste under RCRA (40 CFR 261 33(f)).
• Wastes Exempted as Solid Wastes under RCRA: Certain COUs of formaldehyde may
generate wastes of formaldehyde that are exempted as solid wastes under 40 CFR 261.4(a). For
example, the generation and legitimate reclamation of hazardous secondary materi als of
form aldehyde may be exempt as solid waste.
Figure 3-9 shows a typical hazard waste disposal process.
Recycling
Hazardous Waste
Generation
Hazardous Waste
Transportation
Treatment
Figure 3-9. Typical Hazard Waste Disposal Process (J.S. EPA, 2017a)
3.30.1.2 Worker Activities
For this OES, workers are potentially exposed to formaldehyde during waste handling activities and
equipment cleaning activities. EPA did not i dentify any information to indicate the extent of use of PPE
by the workers in processes using formaldehyde in disposal.
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ONUs include employees (e.g., supervisors, managers) at disposal sites who do not directly handle
formaldehyde. Therefore, the ONUs are expected to have lower inhalation exposures, lower vapor-
through-skin uptake, and no expected dermal exposure.
3.30.1.3 Inhalation Exposure Estimates
The information and data quality valuation to assess occupational exposures during worker handling of
wastes is listed in Table 3-63 and described in detail below. Table 3-64 summarizes the monitoring data
for worker handling of wastes.
Table 3-63. Worker Handling of Wastes Inhalation Exposure Data Evaluation
Worker Activity or
Sampling Location
Data Type
Number of
Samples
Overall Data Quality
Determination
Source
Unknown
PBZ monitoring data
8
Medium
(OSHA. 2019)
Sampling at wastewater
treatment plants
PBZ
16
High
(Teixeira et al..
2013)
OSHA sampled four companies in the hazardous waste treatment and disposal and other nonhazardous
waste treatment and disposal sectors. The 8-hour TWA were calculated from three companies. Only one
sampling data points was monitored for 15-minute, which was below the detection limit. There were 14
samples monitored between 132 to 243 minutes. The methodology for obtaining and analyzing this data
is described in Section 2.5.1. Short-term data were also available from an assessment of indoor airborne
contamination at a wastewater treatment plant in Portugal. The study sampled bar rack chambers,
sedimentation tank, sludge thickeners, sludge dehydration chambers, sludge disposal areas, and an
outdoor control sampling point (Teixeira et al.. 2013). The study recorded 24 different data points, with
8 being reported as not determined. Of note, because formaldehyde does not persist in water, exposures
are expected to be lower than other waste treatment and disposal methods.
It should be noted that 50 percent of the worker 8-hour TWA samples, 29 percent of the greater than 15-
minute to less than 330-minute worker, and the only 15-minute data samples measured below the LOD.
To estimate exposure concentrations for these data, EPA followed the Guidelines for Statistical Analysis
of Occupational Exposure Data (U. 4a), as discussed in Section 2.5.1.
Data is not available to estimate ONU exposures; EPA estimates that ONU exposures are lower than
worker exposures since ONUs do not typically directly handle chemicals.
The high-end and central tendency values for the 8-hour TWA and short-term data represent the
maximum and 50th percentile, respectively. The calculated values are summarized in Table 3-64.
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Table 3-64. Summary of Inhalation Exposure IV
onitoring Data for Worker Hanc
ling of Wastes
Exposure
Concentration
Type
Worker Exposures
Number
of
Worker
Samples
ONU
Exposures
Number
of ONU
Samples
Data Quality
Rating of Air
Concentration
Data
Central
Tendency
(ppm)
High-
End
(ppm)
Central
Tendency
(ppm)
Full shift
8-hour TWA
0.03
0.05
4
0.03
0
Medium
Short-term
15-minute
0.07
0.15
1
EPA did not identify
short-term data for
ONUs
Medium
>15 to <330
minutes
(Wastewater
Treatment Plant-
Area)
0.005
0.01
16
High
>15 to <330
minutes
(OSHA CEHD)
0.02
0.11
12
Medium
>14 to <60
minutes
0.07
0.15
1
Medium
3.30.1.4 Dermal Exposure Estimates
EPA modeled dermal loading using a modified version of the EPA/OPPT 1- and 2-Hand Dermal
Exposure to Liquids Models, as discussed in Section 2.6. The maximum concentration assessed for this
OES was 1.3 percent, based on data from a study on formaldehyde in waste effluent (Lebkowska et at..
2013). Of note, formaldehyde does not persist in water, so concentration is expected to decline through
the process. The calculated occupational dermal exposures for this OES are 18.2 |ig/cm2 as the central
tendency value and 27.3 |ig/cm2 as the high-end value.
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4 WEIGHT OF SCIENTIFIC EVIDENCE: OCCUPATIONAL
EXPOSURE ESTIMATES
EPA's general approach for estimating inhalation exposures is explained in Section 2.5 and the specific
approach and results is discussed for each OES in the relevant subsection of Section 33. Exposure
estimates were divided into full-shift (e.g., 8-hour TWA), and into short-term periods (e.g., 15-minute)
of monitored worker data.
Monitoring data was available to support exposure estimates for all TSCA COUs except for four TSCA
COUs that relied on modeled estimates: (1) Industrial use - non-incorporative activities - process aid in:
oil and gas drilling, extraction, and support activities; process aid specific to petroleum production,
hydraulic fracturing; (2) Commercial use - chemical substances in automotive and fuel products -
automotive care products; lubricants and greases; fuels and related products; (3) Commercial use -
chemical substances in agriculture use products - lawn and garden products; and (4) Commercial use -
chemical Substances in treatment products - water treatment products.
Across COUs for short-term inhalation exposure estimates, the central tendency estimates ranged from
0.02 to 1.63 ppm and high-end estimates ranged from 0.06 to 171 ppm. The TSCA COU of
Manufacturing showed formaldehyde concentrations above other scenarios, with high-end and central
tendency results of 171 ppm and 0.6 ppm for 15-min, respectively. The underlying scenario was based
on monitoring data from manufacturing sites within the US, which included job tasks where workers
wore respiratory protection.
Across COUs for full shift inhalation estimates, the results ranged from 9.34* 10"6 to 0.44 ppm for the
central tendency results, and 0.007 to 14 ppm for the high-end results. The TSCA COU of Commercial
use - chemical substances in automotive and fuel products - automotive care products; lubricants and
greases; fuels and related products showed formaldehyde concentrations above other scenarios, with
high-end and central tendency results of 13.9 and 0.44 ppm, respectively. The underlying scenario was
modeled using a Monte Carlo simulation, assumed that no engineering controls were present, and that
formaldehyde within the automotive care product is completely evaporated during application.
EPA's general approach for estimating dermal exposures is explained in Section 2.6 and the specific
basis for each OES in the relevant subsection of Section 3. All dermal retained doses are per event.
The dermal exposure estimates ranged from 0.56 to 1140 |ig/cm2 for central tendency exposures and
0.84 to 3,090 |ig/cm2for high-end exposures. The highest dermal exposure estimates (HE: 3,090 |ig/m3)
were where manual spray applications were expected. This is based on the EPA assumption that workers
dermal loading during hand spraying conditions might be similar to an immersive dermal contact.
4.1 Strengths, Limitations, Assumptions, and Key Sources of Uncertainty
for the Inhalation Exposure Assessment
Exposure Monitoring Data
The risk evaluation uses existing worker exposure monitoring data to assess exposure to formaldehyde
during some COUs, depending on availability of data. To analyze the exposure data, EPA categorized
each data point as either "worker" or "occupational non-user." The categorizations are based on
descriptions of worker job activity as provided in literature and EPA's judgment. In general, samples for
employees that are expected to have the highest exposure from direct handling of formaldehyde are
categorized as "worker" and samples for employees that are expected to have the lower exposure and do
not directly handle formaldehyde are categorized as "occupational non-user."
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Where sufficient monitoring data were reasonably available, the 95th and 50th percentile exposure
concentrations were calculated using reasonably available monitoring data. The 95th percentile exposure
concentration is intended to represent a high-end exposure level, while the 50th percentile exposure
concentration represents a central tendency exposure level. The underlying distribution of the data, as
well as the representativeness of the reasonably available data, are not known. Where discrete data were
not reasonably available, EPA used reported statistics {i.e., 50th and 95th percentile). Because EPA
could not verify these values, there is an uncertainty.
The primary strength of the approach is that the monitoring data were chemical-specific and directly
applicable to the exposure scenario. The use of applicable monitoring data are preferable to other
assessment approaches such as modeling or the use of OELs/PELs.
The principal limitation of the monitoring data is the uncertainty in the representativeness of the data
due to some scenarios having limited exposure monitoring data in literature. Where few data are
available, the assessed exposure levels are unlikely to be representative of worker exposure across the
entire job category or industry. This may particularly be the case when monitoring data were available
for only one site. Additionally, site locations may introduce uncertainty, because OSHA and NIOSH
reports tend to target facilities based on worker complaints. Differences in work practices and
engineering controls across sites can introduce variability and limit the representativeness of monitoring
data.
Age of the monitoring data can also introduce uncertainty due to differences in workplace practices and
equipment used at the time the monitoring data were collected compared those currently in use.
Therefore, older data may overestimate or underestimate exposures, depending on these differences. The
effects of these uncertainties on the occupational exposure assessment are unknown as the uncertainties
may result in either overestimation or underestimation of exposures—depending on the actual
distribution of formaldehyde air concentrations and the variability of work practices among different
sites.
Exposure Modeling
A strength of the assessment is the variation of the model input parameters as opposed to using a single
static value. This parameter variation increases the likelihood of true occupational inhalation exposures
falling within the range of modeled estimates. An additional strength is that all data that EPA used to
inform the modeling parameter distributions have overall data quality determinations of either high or
medium from the Agency's systematic review process.
However, there is uncertainty as to the representativeness of the parameter distributions with respect to
the modeled scenario because the data are often not specific to sites that use formaldehyde. In general,
the effects of these uncertainties on the exposure estimates are unknown, as the uncertainties may result
in either overestimation or underestimation on exposures depending on the actual distributions of each
of the model input parameters.
There is uncertainty as to whether the model equations generate results that represent actual workplace
air concentrations. Some activity-based modeling may not account for exposures from other sources.
Another uncertainty is lack of consideration of engineering controls. The GS/ESDs assume that all
activities occur without any engineering controls or PPE and in an open-system environment where
vapor and particulates freely escape and can be inhaled. Actual exposures may be less than estimated
depending on engineering control and PPE use.
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4.1.1 Manufacturing of Formaldehyde
EPA has concluded that for the full shift estimates that the weight of scientific evidence is moderate to
robust.
• EPA considered the assessment approach, the quality of the data, and uncertainties in
assessment. Exposure to workers at formaldehyde manufacturing sites is assessed using
formaldehyde personal breathing zone monitoring data collected at workplaces directly
applicable to this OES.
• The data were determined to have quality ratings ranging from medium to high, through EPA's
systematic review process. Specifically, the data were determined to be recent and representative
in geography. Additionally, there were many 8-hour TWA worker samples. Another strength of
the 8-hour TWA estimates is that it incorporates monitoring data from 16 of the 38 current
manufacturers. Most of the sources provide metadata including sample type and sample duration
but lacked worker activities and process information.
• One of the major sources used lacked additional meta-data on worker activities and the sites
were not specified or differentiated. This leads to some uncertainty on how these measurements
vary from site to site and between worker tasks, and on the relative contributions per site.
• EPA also assumed 250 exposure days per year based on continuous formaldehyde exposure each
working day for a typical worker schedule, it is uncertain whether this captures actual worker
schedules and exposures.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
EPA has concluded that for short-term estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in
assessment. Exposure to workers at formaldehyde manufacturing sites is assessed using
formaldehyde personal breathing zone monitoring data collected at workplaces directly
applicable to this OES.
• The data were determined to have quality ratings ranging from medium to high, through EPA's
systematic review process. Specifically, the data were determined to be recent and representative
in geography. The short-term estimate is based on 5 sites with monitoring occur between 1992 to
2016.
• One of the major sources used lacked additional meta-data on worker activities. This leads to
some uncertainty on how these measurements vary between worker tasks.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
4.1.2 Import and/or Repackaging of Formaldehyde
EPA has concluded that for the full shift estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates. Exposure to workers is assessed using formaldehyde personal breathing zone
monitoring data collected at workplaces directly applicable to this OES.
• The data were determined to have quality ratings ranging from medium to high, through EPA's
systematic review process. Specifically, the data were determined to be recent and representative
in geography.
• EPA also assumed 250 exposure days per year based on continuous formaldehyde exposure each
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working day for a typical worker schedule, it is uncertain whether this captures actual worker
schedules and exposures.
• Additionally, there is uncertainty in the ONU exposures due to a lack of personal breathing zone
data.
• The primary limitation is that OSHA CEHD monitoring data does not include process
information or worker activities; therefore, there is uncertainty as to which worker activities
these data cover and whether all potential worker activities are included in this data.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
EPA has concluded that for the short-term estimates that the weight of scientific evidence is moderate.
• The Agency considered the assessment approach, the quality of the data, and uncertainties in
assessment results to determine a weight of scientific evidence conclusion for the inhalation
exposure estimates. Exposure to workers is assessed using formaldehyde personal breathing zone
monitoring data collected at workplaces directly applicable to this OES.
• The data were determined to have quality ratings ranging from medium to high, through EPA's
systematic review process. Specifically, the data were determined to be recent and representative
in geography.
• The primary limitation is that OSHA CEHD monitoring data does not include process
information or worker activities; therefore, there is uncertainty as to which worker activities
these data cover and whether all potential worker activities are included in this data.
• For 15-minute data, an additional limitation is that 73 percent of the data points were below the
detection limit.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
4.1.3 Processing as a Reactant
EPA has concluded that for the full shift estimates that the weight of scientific evidence is moderate to
robust.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for inhalation exposure estimates.
Exposure to workers at formaldehyde processing sites is assessed using formaldehyde personal
breathing zone monitoring data collected at workplaces directly applicable to this OES.
• The data were determined to have data quality ratings ranging from medium to high, through
EPA's systematic review process. Specifically, the data were determined to be highly reliable
and representative in geography.
• Additionally, there was many worker samples integrated. Most of the sources provide metadata
including sample type and sample duration but lack additional information on worker activities.
• There is a limitation with the OSHA CEHD monitoring data, as it does not include process
information or worker activities; therefore, there is uncertainty as to which worker activities
these data cover and whether all potential worker activities are included in this data.
• One of the major sources used lacked additional meta-data on worker activities and the sites
were not specified or differentiated. This leads to some uncertainty on how these measurements
vary from site to site and between worker tasks, and on the relative contributions per site.
• EPA also assumed 250 exposure days per year based on continuous formaldehyde exposure each
working day for a typical worker schedule, it is uncertain whether this captures actual worker
schedules and exposures.
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• There is some limitation in the 8-hour TWA ONU estimates because 56 percent of the samples
were below the LOD.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
EPA has concluded that for the short-term estimates that the weight of scientific evidence is moderate
to robust.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for inhalation exposure estimates.
Exposure to workers at formaldehyde processing sites is assessed using formaldehyde personal
breathing zone monitoring data collected at workplaces directly applicable to this OES.
• The data were determined to have data quality rating ranging from medium to high, through
EPA's systematic review process. Specifically, the data were determined to be highly reliable
and representative in geography.
• Additionally, there was many worker samples. Most of the sources provide metadata including
sample type and sample duration but lack additional information on worker activities.
• There is a limitation with the OSHA CEHD monitoring data, as it does not include process
information or worker activities; therefore, there is uncertainty as to which worker activities
these data cover and whether all potential worker activities are included in this data.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
4,1,4 Textile Finishing
EPA has concluded that for the full shift estimates that the weight of scientific evidence is moderate to
robust.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates. Exposure to workers at textile finishing sites is assessed using formaldehyde personal
breathing zone monitoring data collected at workplaces directly applicable to this OES.
• The data were determined to have data quality ratings of medium to high through EPA's
systematic review process. Specifically, the data were determined to be highly reliable,
representative in geography, and integrated a large number of monitoring data.
• The OSHA CEHD monitoring data does not include process information or worker activities;
therefore, there is uncertainty as to which worker activities these data cover and whether all
potential worker activities are included in this data.
• EPA also assumed 250 exposure days per year based on continuous formaldehyde exposure each
working day for a typical worker schedule, it is uncertain whether this captures actual worker
schedules and exposures.
• Additionally, there is uncertainty in the ONU exposures due to a lack of personal breathing zone
data.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
EPA has concluded that for the short-term estimates that the weight of scientific evidence is moderate
to robust.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates. Exposure to workers at textile finishing sites is assessed using formaldehyde personal
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breathing zone monitoring data collected at workplaces directly applicable to this OES.
• The data were determined to have data quality ratings of medium to high through EPA's
systematic review process. Specifically, the data were determined to be highly reliable,
representative in geography, and integrated a large number of monitoring data.
• The OSHA CEHD monitoring data does not include process information or worker activities;
therefore, there is uncertainty as to which worker activities these data cover and whether all
potential worker activities are included in this data.
• Of note, more than half of the 15-minute samples were below the LOD.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
4.1.5 Use of Coatings, Paints, Adhesives, or Sealants
EPA has concluded that for the full shift estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates. The primary strength is the use of directly applicable personal breathing zone
monitoring data, which is preferrable to other assessment approaches such as modeling or the use
of OELs/PELs.
• The data were determined to have data quality ratings of medium to high through EPA's
systematic review process. Specifically, the data were determined to be highly reliable,
representative in geography.
• For non-spray applications, the Agency uses two studies conducted in other countries to support
the exposure estimate. EPA expects the activities to be similar but notes that the country of the
study, Norway, has a slightly lower legal formaldehyde exposure limit (0.5 ppm) than the U.S
OSHA PEL (0.75 ppm).
• EPA also assumed 250 exposure days per year based on continuous formaldehyde exposure each
working day for a typical worker schedule, it is uncertain whether this captures actual worker
schedules and exposures.
• Additionally, there is uncertainty in the ONU exposures due to a lack of personal breathing zone
data.
• The OSHA CEHD monitoring data does not include process information or worker activities;
therefore, there is uncertainty as to which process or worker activities these data cover and
whether all potential worker activities are included in this data.
• EPA assumes a wide array of NAICS codes are applicable to paints, coatings, adhesives and
sealants, there is some degree of uncertainty in this assumption. Based on these strengths and
limitations, EPA has concluded that the weight of scientific evidence for this assessment is
moderate for full shift and short-term estimates and provides a plausible estimate of exposures.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
EPA has concluded that for the short-term estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates. The primary strength is the use of directly applicable personal breathing zone
monitoring data, which is preferrable to other assessment approaches such as modeling or the use
of OELs/PELs.
• The data were determined to have data quality ratings of medium to high through EPA's
systematic review process. Specifically, the data were determined to be highly reliable,
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representative in geography.
• For non-spray applications, the primary limitation of this data includes the uncertainty of the
representativeness of this data toward the true distribution of inhalation concentrations in this
scenario.
• The OSHA CEHD monitoring data does not include process information or worker activities;
therefore, there is uncertainty as to which process or worker activities these data cover and
whether all potential worker activities are included in this data.
• For spray or unknown application, EPA assumes a wide array of NAICS codes are applicable to
paints, coatings, adhesives and sealants, there is some degree of uncertainty in this assumption.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
4.1,6 Rubber Product Manufacturing
EPA has concluded that for the full shift estimates that the weight of scientific evidence is moderate to
robust.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for inhalation exposure estimates.
Exposure to workers at rubber product manufacturing sites is assessed using formaldehyde
personal breathing zone monitoring data collected at workplaces directly applicable to this OES.
• The data were determined to have data quality ratings ranging from medium to high, through
EPA's systematic review process. Specifically, the data were determined to be highly reliable,
and representative in geography. Additionally, there was a large number of worker samples.
• Most of the sources provide metadata including job tasks and process information.
• There is some uncertainty in the 8-hour TWA ONU estimates since 58 percent of the samples
were below the LOD.
• EPA also assumed 250 exposure days per year based on continuous formaldehyde exposure each
working day for a typical worker schedule, it is uncertain whether this captures actual worker
schedules and exposures.
• Additionally, area samples were used in lieu of personal breathing zone samples for 8-hour TWA
ONU estimates.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
EPA has concluded that for the short-term estimates that the weight of scientific evidence is moderate
to robust.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for inhalation exposure estimates.
Exposure to workers at rubber product manufacturing sites is assessed using formaldehyde
personal breathing zone monitoring data collected at workplaces directly applicable to this OES.
• The data were determined to have data quality ratings ranging from medium to high, through
EPA's systematic review process. Specifically, the data were determined to be highly reliable,
and representative in geography. Additionally, there was a large number of worker samples.
• Most of the sources provide metadata including job tasks and process information.
• Notably, the uncertainty in the 15-minute estimates may be heighted due to the limited temporal
relevance of the some samples, however it applies only to a few data points. The temporal
representativeness of the data has been considered in the data quality rating of the source.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
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plausible estimate of exposures.
4.1.7 Composite Wood Product Manufacturing
EPA has concluded that for the full shift estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for inhalation exposure estimates.
Exposure to workers at composite wood product manufacturing sites is assessed using
formaldehyde personal breathing zone monitoring data collected at workplaces directly
applicable to this OES.
• The data were determined to have data quality ratings ranging from medium to high, through
EPA's systematic review process. Specifically, the data were determined to be highly reliable,
and representative in geography. Additionally, there was a large number of worker samples.
• Most of the sources provide metadata including sample type and sample duration.
• EPA also assumed 250 exposure days per year based on continuous formaldehyde exposure each
working day for a typical worker schedule, it is uncertain whether this captures actual worker
schedules and exposures.
• Additionally, there is uncertainty in the ONU exposures due to a lack of personal breathing zone
data.
• The OSHA CEHD monitoring data does not include process information or worker activities;
therefore, there is uncertainty as to which process or worker activities these data cover and
whether all potential worker activities are included in this data.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
EPA has concluded that for the short-term estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for inhalation exposure estimates.
Exposure to workers at composite wood product manufacturing sites is assessed using
formaldehyde personal breathing zone monitoring data collected at workplaces directly
applicable to this OES.
• The data were determined to have data quality ratings ranging from medium to high, through
EPA's systematic review process. Specifically, the data were determined to be highly reliable,
and representative in geography. Additionally, there was a large number of worker samples.
• The OSHA CEHD monitoring data does not include process information or worker activities;
therefore, there is uncertainty as to which process or worker activities these data cover and
whether all potential worker activities are included in this data.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
4.1.8 Other Composite Material Manufacturing
EPA has concluded that for the full shift estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates. Exposure to workers at composite material manufacturing sites is assessed using
formaldehyde personal breathing zone monitoring data collected at workplaces directly
applicable to this OES.
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• The data were determined to have data quality rating of medium, through EPA's systematic
review process. Specifically, the data were determined to be highly reliable, and representative in
geography. Most of the sources provide metadata including sample type and sample duration.
• EPA also assumed 250 exposure days per year based on continuous formaldehyde exposure each
working day for a typical worker schedule, it is uncertain whether this captures actual worker
schedules and exposures.
• Additionally, there is uncertainty in the ONU exposures due to a lack of personal breathing zone
data.
• Due to the large variation amongst sites that manufacture composite materials, there is some
uncertainty in how representative the monitoring data is of typical sites.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
EPA has concluded that for the short-term estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates. Exposure to workers at composite material manufacturing sites is assessed using
formaldehyde personal breathing zone monitoring data collected at workplaces directly
applicable to this OES.
• The data were determined to have data quality rating of medium, through EPA's systematic
review process. Specifically, the data were determined to be highly reliable, and representative in
geography. Most of the sources provide metadata including sample type and sample duration.
• There is some uncertainty in the 15-minute and the greater than 14-minute to less than 60-minute
estimates since over 50 percent of the samples were below the LOD.
• Due to the large variation amongst sites that manufacture composite materials, there is some
uncertainty in how representative the monitoring data is of typical sites.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
4.1.9 Paper Manufacturing
EPA has concluded that for the full shift estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates. The primary strength is the use of directly applicable monitoring data, which is
preferrable to other assessment approaches such as modeling or the use of OELs/PELs. EPA
used personal breathing zone air concentration data from OSHA's CEHD, which has a medium
data quality rating from the systematic review process.
• The primary limitation of this data includes the uncertainty of the representativeness of this data
toward the true distribution of inhalation concentrations in this scenario.
• The OSHA CEHD monitoring data does not include process information or worker activities;
therefore, there is uncertainty as to which worker activities these data cover and whether all
potential worker activities are included in this data.
• EPA also assumed 250 exposure days per year based on continuous formaldehyde exposure each
working day for a typical worker schedule; it is uncertain whether this captures actual worker
schedules and exposures.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
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EPA has concluded that for the short-term estimates that the weight of scientific evidence is moderate.
• PA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates. The primary strength is the use of directly applicable monitoring data, which is
preferrable to other assessment approaches such as modeling or the use of OELs/PELs. EPA
used personal breathing zone air concentration data from OSHA's CEHD, which has a medium
data quality rating from the systematic review process.
• The primary limitation of this data includes the uncertainty of the representativeness of this data
toward the true distribution of inhalation concentrations in this scenario.
• The OSHA CEHD monitoring data does not include process information or worker activities;
therefore, there is uncertainty as to which worker activities these data cover and whether all
potential worker activities are included in this data.
• There is some uncertainty in the 15-minute and the greater than 14-minute to less than 60-minute
estimates since over 50 percent of the samples were below the LOD.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
4X10 Plastic Product Manufacturing
EPA has concluded that for the full shift estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the exposure estimates. The
primary strength is the use of directly applicable monitoring data, which is preferrable to other
assessment approaches such as modeling or the use of OELs/PELs.
• EPA used personal breathing zone air concentration data to assess inhalation exposures, which
were determined to have data quality ratings ranging from medium to high, through EPA's
systematic review process.
• The primary limitation of this data includes the uncertainty of the representativeness of this data
toward the true distribution of inhalation concentrations in this scenario.
• In particular as formaldehyde is also possibly produced from the decomposition of the plastic
during heating.
• The OSHA CEHD monitoring data does not include process information or worker activities;
therefore, there is uncertainty as to which worker activities these data cover and whether all
potential worker activities are included in this data.
• EPA also assumed 8-hour exposure hours per day 250 exposure days per year based on
continuous formaldehyde exposure each working day for a typical worker schedule; it is
uncertain whether this captures actual worker schedules and exposures.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
EPA has concluded that for the short-term estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the exposure estimates. The
primary strength is the use of directly applicable monitoring data, which is preferrable to other
assessment approaches such as modeling or the use of OELs/PELs.
• EPA used personal breathing zone air concentration data to assess inhalation exposures, which
were determined to have data quality ratings ranging from medium to high, through EPA's
systematic review process.
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• The primary limitation of this data includes the uncertainty of the representativeness of this data
toward the true distribution of inhalation concentrations in this scenario.
• In particular as formaldehyde is also possibly produced from the decomposition of the plastic
during heating.
• There is some uncertainty in the 15-minute and the greater than 14-minute to less than 60-minute
estimates since over 50 percent of the samples were below the LOD.
• The OSHA CEHD monitoring data does not include process information or worker activities;
therefore, there is uncertainty as to which worker activities these data cover and whether all
potential worker activities are included in this data.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
4.1,11 Processing of Formaldehyde into Formulations, Mixtures, or Reaction Products
EPA has concluded that for the full shift estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the exposure estimates. The
primary strength is the use of directly applicable monitoring data, which is preferrable to other
assessment approaches such as modeling or the use of OELs/PELs.
• EPA used personal breathing zone air concentration data to assess inhalation exposures, which
were determined to have data quality ratings ranging from medium to high, through EPA's
systematic review process. Specifically, the data were determined to be representative in
geography and include a large data pool.
• The primary limitation of this data includes the uncertainty of the representativeness of this data
toward the true distribution of inhalation concentrations in this scenario.
• The OSHA CEHD monitoring data does not include process information or worker activities;
therefore, there is uncertainty as to which worker activities these data cover and whether all
potential worker activities are included in this data.
• EPA also assumed 250 exposure days per year based on continuous formaldehyde exposure each
working day for a typical worker schedule; it is uncertain whether this captures actual worker
schedules and exposures.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
EPA has concluded that for the short-term estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the exposure estimates. The
primary strength is the use of directly applicable monitoring data, which is preferrable to other
assessment approaches such as modeling or the use of OELs/PELs.
• EPA used personal breathing zone air concentration data to assess inhalation exposures, which
were determined to have data quality ratings ranging from medium to high, through EPA's
systematic review process. Specifically, the data were determined to be representative in
geography and include a large data pool.
• The primary limitation of this data includes the uncertainty of the representativeness of this data
toward the true distribution of inhalation concentrations in this scenario.
• The OSHA CEHD monitoring data does not include process information or worker activities;
therefore, there is uncertainty as to which worker activities these data cover and whether all
potential worker activities are included in this data.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
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plausible estimate of exposures.
4.1.12 Recycling
EPA has concluded that for the full shift estimates that the weight of scientific evidence is moderate.
• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. Exposure to workers
and ONUs is assessed using formaldehyde personal breathing zone monitoring data collected at
facilities expected to be recycling products containing formaldehyde.
• The primary limitation of this data includes the uncertainty of the representativeness of this data
toward the true distribution of inhalation concentrations in this scenario.
• EPA also assumed 250 exposure days per year based on continuous formaldehyde exposure each
working day for a typical worker schedule; it is uncertain whether this captures actual worker
schedules and exposures.
• Another limitation is that the OSHA CEHD monitoring data does not include process
information or worker activities; therefore, there is uncertainty as to which worker activities
these data cover and whether all potential worker activities are included in this data.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
EPA has concluded that for the short-term estimates that the weight of scientific evidence is moderate.
• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. Exposure to workers
and ONUs is assessed using formaldehyde personal breathing zone monitoring data collected at
facilities expected to be recycling products containing formaldehyde.
• The primary limitation of this data includes the uncertainty of the representativeness of this data
toward the true distribution of inhalation concentrations in this scenario.
• Another limitation is that the OSHA CEHD monitoring data does not include process
information or worker activities; therefore, there is uncertainty as to which worker activities
these data cover and whether all potential worker activities are included in this data.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
4.1.13 Distribution of Commerce
EPA has concluded that for the full shift estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the exposure estimates.
• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. EPA used personal
breathing zone air concentration data to assess inhalation exposures, which were determined to
have data quality ratings of medium, through EPA's systematic review process.
• The primary limitation of this data includes the uncertainty of the representativeness of this data
toward the true distribution of inhalation concentrations in this scenario.
• The OSHA CEHD monitoring data does not include process information or worker activities;
therefore, there is uncertainty as to which worker activities these data cover and whether all
potential worker activities are included in this data.
• EPA also assumed 250 exposure days per year based on continuous formaldehyde exposure each
working day for a typical worker schedule; it is uncertain whether this captures actual worker
schedules and exposures.
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• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
EPA has concluded that for the short-term estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the exposure estimates.
• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. EPA used personal
breathing zone air concentration data to assess inhalation exposures, which were determined to
have data quality ratings of medium, through EPA's systematic review process.
• The primary limitation of this data includes the uncertainty of the representativeness of this data
toward the true distribution of inhalation concentrations in this scenario.
• The OSHA CEHD monitoring data does not include process information or worker activities;
therefore, there is uncertainty as to which worker activities these data cover and whether all
potential worker activities are included in this data.
• There is some uncertainty in the 15-minute estimates since over 50 percent of the samples were
below the LOD.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
4.1,14 Furniture Manufacturing
EPA has concluded that for the full shift estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates.
• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. EPA used personal
breathing zone air concentration data to assess inhalation exposures, both of which have a
predominantly medium data quality rating from the systematic review process.
• The primary limitation of this data includes the uncertainty of the representativeness of this data
toward the true distribution of inhalation concentrations in this scenario, the lack of worker
descriptions, and temporal relevance due to shifts in regulatory standards.
• TSCA Title IV, which was finalized in 2016, may impact exposure levels; however, limited post-
implementation exposure data is available to assess this impact.
• EPA also assumed 250 exposure days per year based on continuous formaldehyde exposure each
working day for a typical worker schedule; it is uncertain whether this captures actual worker
schedules and exposures.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
EPA has concluded that for the short-term estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates.
• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. EPA used personal
breathing zone air concentration data to assess inhalation exposures, both of which have a
predominantly medium data quality rating from the systematic review process.
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• The primary limitation of this data includes the uncertainty of the representativeness of this data
toward the true distribution of inhalation concentrations in this scenario, the lack of worker
descriptions, and temporal relevance due to shifts in regulatory standards.
• TSCA Title IV, which was finalized in 2016, may impact exposure levels; however, limited post-
implementation exposure data is available to assess this impact.
• There is some uncertainty in the 15-minute estimates since over 50 percent of the samples were
below the LOD.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
4X15 Processing Aid
EPA has concluded that for the full shift estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the exposure estimates.
• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. EPA used personal
breathing zone air concentration data to assess inhalation exposures, both of which have a
medium data quality rating from the systematic review process.
• The primary limitation of this data includes the uncertainty of the representativeness of this data
toward the true distribution of inhalation concentrations in this scenario, the lack of worker
descriptions, and the datedness of the samples.
• EPA also assumed 8-hour exposure hours per day 250 exposure days per year based on
continuous formaldehyde exposure each working day for a typical worker schedule; it is
uncertain whether this captures actual worker schedules and exposures.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
EPA has concluded that for the short-term estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the exposure estimates.
• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. EPA used personal
breathing zone air concentration data to assess inhalation exposures, both of which have a
medium data quality rating from the systematic review process.
• The primary limitation of this data includes the uncertainty of the representativeness of this data
toward the true distribution of inhalation concentrations in this scenario, the lack of worker
descriptions, and the datedness of the samples.
• There is some uncertainty in some of the short-term estimates since over 50 percent of the
samples were below the LOD.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
4,1.16 Use of Formaldehyde for Oilfield Well Production
EPA has concluded that for the full shift and short-term estimates that the weight of scientific evidence
is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the exposure estimates.
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• Inhalation exposure estimates are assessed using Monte Carlo modeling with information from
the ESD on Hydraulic Fracturing and FracFocus 3.0 reported information on formaldehyde use
which increases the strength of evidence for this OES as parameters are directly relevant to the
OES (as opposed to surrogate) and formaldehyde.
• The ESD on Hydraulic Fracturing and FracFocus 3.0 have medium overall data quality
determinations, high number of data points (simulation runs), and full distributions of input
parameters.
• The Monte Carlo modeling accounts for the entire distribution of input parameters, calculating a
distribution of potential exposure values that represents a larger proportion of sites than a
discrete value.
• Factors that decrease the strength of the evidence for this OES include that the ESD has not been
peer reviewed and the uncertainties and limitations in the representativeness of the estimates for
sites that specifically use formaldehyde because the default values from the ESD on Hydraulic
Fracturing.
• Additionally, the duration of exposure for container unloading and cleaning activities is
uncertain. To avoid unrealistic output parameters, exposure duration was capped at 2 hours for
each activity. This is a limitation of the assessment because there is uncertainty in the extent to
which the assessed activity durations are representative of real-world conditions.
• EPA also assumed 8-hour exposure hours per day 250 exposure days per year based on
continuous formaldehyde exposure each working day for a typical worker schedule; it is
uncertain whether this captures actual worker schedules and exposures.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
4.1.17 Industrial Use of Lubricants
EPA has concluded that for the full shift and short-term estimates that the weight of scientific evidence
is moderate.
• Eight-hour TWA inhalation exposure estimates are assessed using Monte Carlo modeling with
information from the OECD ESD on Chemical Additives used in Automotive Lubricants, and
EPA/OPPT models.
• Factors that increase the strength of evidence for this OES are that the ESD and has high overall
data quality, high number of data points (simulation runs), and full distributions of input
parameters (OE 00).
• The Monte Carlo modeling accounts for the entire distribution of input parameters, calculating a
distribution of potential exposure values that represents a larger proportion of sites than a
discrete value.
• Factors that decrease the strength of the evidence for this OES include that the ESD is not
directly applicable to industrial use of lubricants, uncertainty in the representativeness of
evidence to all sites, and uncertainty in the use of generic default values from the ESD for sites
that specifically use formaldehyde.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
4.1.18 Foundries
EPA has concluded that for the full shift estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
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estimates.
• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. EPA used personal
breathing zone air concentration data to assess inhalation exposures, which have a medium to
high data quality rating from the systematic review process.
• The primary limitation of this data includes the uncertainty of the representativeness of this data
toward the true distribution of inhalation concentrations in this scenario, and lack of worker job
descriptions.
• EPA also assumed 250 exposure days per year based on continuous formaldehyde exposure each
working day for a typical worker schedule; it is uncertain whether this captures actual worker
schedules and exposures.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
EPA has concluded that for the short-term estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates.
• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. EPA used personal
breathing zone air concentration data to assess inhalation exposures, which have a medium to
high data quality rating from the systematic review process.
• The primary limitation of this data includes the uncertainty of the representativeness of this data
toward the true distribution of inhalation concentrations in this scenario, and lack of worker job
descriptions.
• For 15-minute data, an additional limitation is that 87 percent of the data points were below the
detection limit.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
4,1,19 Installation and Demolition of Formaldehyde-Based Furnishings and
Building/Construction Materials in Residential, Public, and Commercial Buildings,
and Other Structures
EPA has concluded that for the full shift estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates.
• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. EPA used personal
breathing zone air concentration data to assess inhalation exposures, which have a medium data
quality rating from the systematic review process.
• The primary limitation of this data includes the uncertainty of the representativeness of this data
toward the true distribution of inhalation concentrations in this scenario, and lack of personal
breathing zone ONU data.
• EPA also assumed 250 exposure days per year based on continuous formaldehyde exposure each
working day for a typical worker schedule; it is uncertain whether this captures actual worker
schedules and exposures.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
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plausible estimate of exposures.
EPA has concluded that for the short-term estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates.
• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. EPA used personal
breathing zone air concentration data to assess inhalation exposures, which have a medium data
quality rating from the systematic review process.
• The primary limitation of this data includes the uncertainty of the representativeness of this data
toward the true distribution of inhalation concentrations in this scenario, and lack of personal
breathing zone ONU data.
• For some of the short-term estimates, more than 50 percent of the samples were below the LOD.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
4,1.20 Use of Formulations containing Formaldehyde for Water Treatment
EPA has concluded that for the full shift and short-term estimates that the weight of scientific evidence
is moderate.
• Inhalation exposure estimates are assessed using EPA/OPPT models.
• Factor that increase the strength of evidence for this OES is that the Tank Truck and Rail car
Loading and Unloading Release and Inhalation Exposure Model is more robust than other
EPA/OPPT standard models for assessing inhalation exposure.
• Factors that decrease the strength of the evidence for this OES are that:
o After each loading event, the model assumes saturated air containing formaldehyde that
remains in the transfer hose and/or loading arm is released to air. The model calculates
the quantity of saturated air using design dimensions of loading systems published in the
OPW Engineered Systems catalog and engineering judgment. These dimensions may not
be representative of the whole range of loading equipment used at industrial facilities,
o The model estimates fugitive emissions from equipment leaks using total organic
compound emission factors from EPA's Protocol for Equipment Leak Emission
Estimates (U.S. EPA, 1995), and engineering judgement on the likely equipment type
used for transfer (e.g., number of valves, seals, lines, connections). The applicability of
these emission factors to formaldehyde, and the accuracy of EPA's assumption on
equipment type are not known,
o The model assumes the use of a vapor balance system to minimize fugitive emissions.
Although most industrial facilities are likely to use a vapor balance system when
loading/unloading volatile chemicals, EPA does not know whether these systems are used
by all facilities that potentially handle formaldehyde,
o The model does not account for other potential sources of exposure at industrial facilities,
such as sampling, equipment cleaning, and other process activities that can contribute to a
worker's overall 8-hour daily exposure. These model uncertainties could result in an
underestimate of the worker 8-hour exposure.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
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4.1.21 Use of Formulations Containing Formaldehyde in Laundry and Dishwashing
Products
EPA has concluded that for the full shift and short-term estimates that the weight of scientific evidence
is slight.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates.
• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. EPA used personal
breathing zone air concentration data to assess 8-hour inhalation exposures, which has a high
data quality rating from the systematic review process.
• The Agency used an area source for the short-term exposure as it was the only value available,
however the source states that the sample is between the minimum detectable and minimum
quantifiable concentration. This leads to more uncertainty associated with the short-term
exposure value.
• The primary limitation of this data includes the uncertainty of whether the scenario covers
industrial use of the type of laundry products identified, limited use information, and that over 50
percent of the 8-hour TWA data for workers were reported as below the LOD.
• EPA also assumed 250 exposure days per year based on continuous formaldehyde exposure each
working day for a typical worker schedule; it is uncertain whether this captures actual worker
schedules and exposures.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
4.1.22 Use of Electronic and Metal Products
EPA has concluded that for the full shift estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates.
• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. EPA used personal
breathing zone air concentration data to assess inhalation exposures, which has a medium data
quality rating from the systematic review process.
• The OSHA CEHD monitoring data does not include process information or worker activities;
therefore, there is uncertainty as to which worker activities these data cover and whether all
potential worker activities are included in this data.
• EPA also assumed 8-hour exposure hours per day 250 exposure days per year based on
continuous formaldehyde exposure each working day for a typical worker schedule; it is
uncertain whether this captures actual worker schedules and exposures.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
EPA has concluded that for the short-term estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates.
• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. EPA used personal
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breathing zone air concentration data to assess inhalation exposures, which has a medium data
quality rating from the systematic review process.
• The OSHA CEHD monitoring data does not include process information or worker activities;
therefore, there is uncertainty as to which worker activities these data cover and whether all
potential worker activities are included in this data.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
4.1.23 Use of Formulations Containing Formaldehyde in Automotive Care Products
EPA has concluded that for the full shift and short-term estimates that the weight of scientific evidence
is moderate.
• Inhalation exposure estimates are assessed using Monte Carlo modeling with information from
the GS on Commercial Use of Automotive Detailing Products ( (22b).
• Factors that increase the strength of evidence for this OES are that the GS has high overall data
quality, high number of data points (simulation runs), and full distributions of input parameters
(U.S. EPA. 2022b). The Monte Carlo modeling accounts for the entire distribution of input
parameters, calculating a distribution of potential exposure values that represents a larger
proportion of sites than a discrete value.
• Factors that decrease the strength of the evidence for this OES include uncertainty in the
representativeness of evidence to all sites and uncertainty in the use of generic default values
from the GS for sites that specifically use formaldehyde.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
4.1.24 Use of Automotive Lubricants
EPA has concluded that for the full shift estimates that the weight of scientific evidence is slight to
moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates.
• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. EPA used personal
breathing zone air concentration data to assess inhalation exposures, which has a medium data
quality rating from the systematic review process.
• The primary limitation of this data includes the uncertainty of the representativeness of this data
toward the true distribution of inhalation concentrations in this scenario.
• EPA also assumed 8-hour exposure hours per day 250 exposure days per year based on
continuous formaldehyde exposure each working day for a typical worker schedule; it is
uncertain whether this captures actual worker schedules and exposures.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
EPA has concluded that for the short-term estimates that the weight of scientific evidence is slight to
moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates.
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• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. EPA used personal
breathing zone air concentration data to assess inhalation exposures, which has a medium data
quality rating from the systematic review process.
• The primary limitation of this data includes the uncertainty of the representativeness of this data
toward the true distribution of inhalation concentrations in this scenario. All of the short-term
exposure estimates have higher than 50 percent of the samples below the detection limit.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
4,1,25 Use of Formulations Containing Formaldehyde in Fuel
EPA has concluded that for the full shift estimates that the weight of scientific evidence is slight to
moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates.
• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. EPA used personal
breathing zone air concentration data to assess 8-hour and short-term inhalation exposures,
which have a medium to high data quality rating from the systematic review process.
• The primary limitations of this data includes the uncertainty of the representativeness of this data
toward the true distribution of inhalation concentrations in this scenario and the limited data
pool. Although, EPA identified non-discrete data specific to the occupational scenarios, which
addresses use of fuel at gas stations.
• The Agency also assumed 250 exposure days per year based on continuous formaldehyde
exposure each working day for a typical worker schedule; it is uncertain whether this captures
actual worker schedules and exposures.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
EPA has concluded that for the short-term estimates that the weight of scientific evidence is slight to
moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates.
• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. EPA used personal
breathing zone air concentration data to assess 8-hour and short-term inhalation exposures,
which have a medium to high data quality rating from the systematic review process.
• The primary limitation of this data includes the uncertainty of the representativeness of this data
toward the true distribution of inhalation concentrations in this scenario and the limited data
pool. Although, EPA identified non-discrete data specific to the occupational scenarios, which
addresses use of fuel at gas stations.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
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4.1.26 Use of Fertilizer Containing Formaldehyde in Outdoor Use Products
EPA has concluded that for the full shift and short-term estimates that the weight of scientific evidence
is moderate.
• Inhalation exposure estimates are assessed using Monte Carlo modeling with information from
the ChemSTEER User Guide for the EPA/OPPTMass Balance Inhalation Model (
2015b) and Chemical Engineering Branch Manual for the Preparation of Engineering
Assessments, Volume 1 (U.S. EPA. 1991a) and EPA/OPPT models.
• Factors that increase the strength of evidence for this OES are the high number of data points
(simulation runs), and full distributions of input parameters. The Monte Carlo modeling accounts
for the entire distribution of input parameters, calculating a distribution of potential exposure
values that represents a larger proportion of sites than a discrete value.
• Factors that decrease the strength of the evidence for this OES include that the exposure points
were not identified using a GS/ESD, uncertainty in the representativeness of evidence to all sites,
and uncertainty in the use of generic default values from the aforementioned reports for sites that
specifically use formaldehyde.
• The application amount of fertilizer was determined using nitrogen use for corn in the U.S., the
application of fertilizer per application will likely vary by crop, soil type, and region. This is an
uncertainty in the assessment.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
4.1.27 Use of Explosives
EPA has concluded that for the full shift estimates that the weight of scientific evidence is slight.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates.
• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. EPA used personal
breathing zone air concentration data to assess 8-hour and 15-minute (peak) inhalation
exposures, which have a medium data quality rating from the systematic review process.
• The primary limitations of this data includes on whether the formaldehyde exposure measured at
the military sites were from explosives or other sources of formaldehyde as well as the limited
data pool.
• EPA also assumed 250 exposure days per year based on continuous formaldehyde exposure each
working day for a typical worker schedule; it is uncertain whether this captures actual worker
schedules and exposures.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
EPA has concluded that for the short-term estimates that the weight of scientific evidence is slight.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates.
• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. EPA used personal
breathing zone air concentration data to assess 8-hour and 15-minute (peak) inhalation
exposures, which have a medium data quality rating from the systematic review process.
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• The primary limitations of this data includes on whether the formaldehyde exposure measured at
the military sites were from explosives or other sources of formaldehyde as well as the limited
data pool.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
4.1.28 Use of Packaging, Paper, Plastics, and Hobby Products
EPA has concluded that for the full shift and short-term estimates that the weight of scientific evidence
is slight.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates.
• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. EPA used personal
breathing zone air concentration data to assess 8-hour inhalation exposures, which has a medium
data quality rating from the systematic review process. For these exposures, EPA only used two
samples to estimate 8-hour.
• EPA also assumed 8-hour exposure hours per day 250 exposure days per year based on
continuous formaldehyde exposure each working day for a typical worker schedule; it is
uncertain whether this captures actual worker schedules and exposures.
EPA has concluded that for the short-term estimates that the weight of scientific evidence is slight.
• For short-term exposures, EPA used four data samples. In addition, there is uncertainty on
whether the primary source of formaldehyde in these mail delivery services is from the
packaging and paper.
• Based on these strengths and limitations, EPA has concluded that the weight of scientific
evidence for this assessment is slight for both the full shift and short-term exposure estimates yet
provides a plausible estimate of exposures.
4.1.29 Use of Craft Materials
EPA has concluded that for the full shift and short-term estimates that the weight of scientific evidence
is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates.
• The primary strength is the use of personal breathing zone air concentration data to assess
inhalation exposures, which has a medium to high data quality rating from the systematic review
process.
• The primary limitation of this data is that the monitoring data is not specific to use of craft
materials. It includes surrogate monitoring data sampled at industrial sites that may overestimate
exposures for use of craft paints and adhesives.
• Furthermore, EPA also assumed 8-hour exposure hours per day 250 exposure days per year
based on continuous formaldehyde exposure each working day for a typical worker schedule; it
is uncertain whether this captures actual worker schedules and exposures.
• Based on these strengths and limitations, EPA has concluded that the weight of scientific
evidence for this assessment is moderate yet provides a plausible estimate of exposures.
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4.1.30 Use of Printing Ink, Toner, and Colorant Products Containing Formaldehyde
EPA has concluded that for the full shift and short-term estimates that the weight of scientific evidence
is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates.
• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. EPA used personal
breathing zone air concentration data to assess inhalation exposures, which has a medium to high
data quality rating from the systematic review process.
• The primary limitation of this data includes the uncertainty of the representativeness of this data
toward the true distribution of inhalation concentrations in this scenario.
• For short-term exposure estimates, more than 50 percent of the sample data monitored for 15-
minute and sampled between 15 minutes to 60 minutes were non-detects, which introduces an
uncertainty on the estimates estimated. However, the percentage of samples reported as non-
detect for samples monitored for less than 330 minutes was only 23 percent.
• EPA also assumed 250 exposure days per year based on continuous formaldehyde exposure each
working day for a typical worker schedule; it is uncertain whether this captures actual worker
schedules and exposures.
• Based on these strengths and limitations, EPA has concluded that the weight of scientific
evidence for this assessment is moderate for the exposure estimates
4.1.31 Photo Processing Using Formulations Containing Formaldehyde
EPA has concluded that for the full shift and short-term estimates that the weight of scientific evidence
is slight to moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates.
• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. EPA used personal
breathing zone air concentration data to assess inhalation exposures, which has a medium data
quality rating from the systematic review process.
• The primary limitation of this data includes the limited data pool and the sample dates, with a
majority being between 1993 and 1999.
• EPA also assumed 250 exposure days per year based on continuous formaldehyde exposure each
working day for a typical worker schedule; it is uncertain whether this captures actual worker
schedules and exposures.
• For short-term exposure estimates, more than 50 percent of the sample data monitored for 15-
minute and sampled between 15 minutes to 60 minutes were non-detects, which introduces an
uncertainty on the estimates estimated. However, the percentage of samples reported as non-
detect for samples monitored for less than 330 minutes was only 20 percent.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
4.1.32 General Laboratory Use
EPA has concluded that for the full shift and short-term estimates that the weight of scientific evidence
is moderate to robust.
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EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates.
The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. EPA used personal
breathing zone air concentration data to assess inhalation exposures, which have a medium data
quality rating from the systematic review process. The exposure estimates are supported by a
large number of workplace sampling data.
The primary limitations of this data includes the uncertainty of the representativeness of this data
toward the true distribution of inhalation concentrations in this scenario, and the limited short-
term available.
EPA also assumed 250 exposure days per year based on continuous formaldehyde exposure each
working day for a typical worker schedule; it is uncertain whether this captures actual worker
schedules and exposures.
Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
4,1.33 Worker Handling of Waste
EPA has concluded that for the full shift estimates that the weight of scientific evidence is slight to
moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates.
• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. EPA used personal
breathing zone air concentration data to assess inhalation exposures, which have a medium to
high data quality rating from the systematic review process.
• The primary limitation of this data includes the limited data pool, as well as the limited
geographical representativeness.
• EPA also assumed 250 exposure days per year based on continuous formaldehyde exposure each
working day for a typical worker schedule; it is uncertain whether this captures actual worker
schedules and exposures.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
EPA has concluded that for the short-term estimates that the weight of scientific evidence is moderate.
• EPA considered the assessment approach, the quality of the data, and uncertainties in assessment
results to determine a weight of scientific evidence conclusion for the inhalation exposure
estimates.
• The primary strength is the use of directly applicable monitoring data, which is preferrable to
other assessment approaches such as modeling or the use of OELs/PELs. EPA used personal
breathing zone air concentration data to assess inhalation exposures, which have a medium to
high data quality rating from the systematic review process.
• The primary limitations of this data includes the uncertainty of the representativeness of this data
toward the true distribution of inhalation concentrations in this scenario.
• Based on these strengths and uncertainties, EPA determined that the exposure estimate provide a
plausible estimate of exposures.
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4.2 Strengths, Limitations, Assumptions, and Key Sources of Uncertainty
for the Dermal Exposure Assessment
The EPA/OPPT 1- and 2-Hand Dermal Exposure to Liquids Models are used to estimate dermal
exposure to formaldehyde in occupational settings. The model assumes a single exposure event per day
based on existing framework of the EPA/OPPT 1- and 2-Hand Dermal Exposure to Liquids Models and
does not address variability in exposure duration and frequency. The underlying values of the quantity
remaining on the skin (Qu) were based on experimental studies of non-aqueous liquids to measure the
quantity remaining on the skin after contact. In this study, an initial wipe test was performed that
consisted of the subjects wiping their hands with a cloth saturated in the liquid. The amount of liquid
retained on the hands was measured immediately after the application. The study did not take into
consideration the fact that liquid retention on the skin may vary with individuals and techniques of
application and removal from the hands. Also, the data used were developed from three kinds of oils;
therefore, the data may be less applicable to other liquids ( 2b).
Data on dermal exposure measurements at facilities that manufacture, process, and use chemicals are
limited, below includes measured data that can be used for comparison with the dermal loading values
used in this assessment. The experimental dermal loading values used in this assessment are comparable
to measured values recorded in the Pesticide Handlers Exposure Database (PHED) (per SAIC, 1996)
[Docket ID: EPA-HQ-OPPT-2024-0114-0051],
Table 4-1. Comparison of Dermal Exposure Values
Dermal Exposure
Value
Type of Data
Notes
Reference
1.4 mg/cm2-event
(central tendency)
2.1 mg/cm2-event
(high-end)
Experimental
Used in EPA/OPPT Dermal
Contact with Liquids Models
OPPT Dermal
Framework
Underlying data from
(US. EPA. 1992b")
1.3-10.3 mg/cm2-
event
Experimental
Used in EPA/OPPT 2-Hand
Dermal Immersion in Liquid
Model
OPPT Dermal
Framework
Underlying data from
(US. EPA. 1992b")
2.9 mg
metalworking
fluid/cm2-hr
(geometric mean)
Measured
Study of dermal exposures to
electroplating and metalworking
fluids during metal shaping
operations
Roff, 2004 as reported
in OECD ESD on
Metalworking Fluids
0 )
0.5-1.8 mg/cm2
Measured
Dermal exposure data for workers
involved in pesticide mixing and
loading. The data included
various combinations of
formulation type and
mixing/loading methods.
1992 PEHD (per SAIC,
1996) [Docket ID: EPA-
HQ-OPPT-2024-0114-
0051]
0.0081-505.4
mg/day
Measured
PMN manufacturer study of
unprotected dermal exposures to
trichloroketone for maintenance
workers
Anonymous, 1996 (per
SAIC, 1996) [Docket
ID: EPA-HQ-OPPT-
2024-0114-0051]
Page 154 of 313
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Dermal Exposure
Value
Type of Data
Notes
Reference
0.0071-2.457
mg/day
Measured
PMN manufacturer study of
unprotected dermal exposures to
trichloroketone for process
operators
Anonymous, 1996 (per
SAIC, 1996) [Docket
ID: EPA-HQ-OPPT-
2024-0114-0051]
0.0105-0.0337
mg/day
Measured
PMN manufacturer study of
protected dermal exposures to
trichloroketone for maintenance
workers
Anonymous, 1996 (per
SAIC, 1996) [Docket
ID: EPA-HQ-OPPT-
2024-0114-0051]
0.0098-0.2417
mg/day
Measured
PMN manufacturer study of
protected dermal exposures to
trichloroketone for process
operators
Anonymous, 1996 (per
SAIC, 1996) [Docket
ID: EPA-HQ-OPPT-
2024-0114-0051]
EPA had moderate weight of scientific evidence conclusions for all dermal scenarios assessed. The
primary strength of the dermal assessment is that most of the data that the Agency used to inform the
modeling parameter distributions have overall data quality determinations of either high or medium
from EPA's systematic review process, such as the 2020 CDR ( |20a). There are some
limitations due to limited information on the range of formaldehyde weight concentrations for the
process or product. In addition, EPA assumed that workers' dermal loading during hand spraying
conditions may be similar to an immersive dermal contact as EPA expects the presence of mists in the
workspace that may deposit on the workers skin to result in a dermal load that exceeds the dermal
loading values associated with routine/incidental contact typically assessed for activities such as
container unloading. This assumption is consistent with the approaches suggested in the Use of
Adhesives ESD and Application of Radiation Curable Coatings ESD (OE », 201 lb). Based on
these strengths and limitations, EPA has assigned a moderate weight of scientific evidence.
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REFERENCES
A.CA. (21 . Comment submitted by Raleigh Davis, Assistant Director and Riaz Zaman, Counsel,
Government Affairs, American Coatings Association (ACA) regarding the proposed 20 high
priority candidates for chemical risk evaluation. Available online at
https://www.reeiilations.eov/comment/EPA-HQ-OPPT-2018-0438-0004
. Comment submitted by Kimberly Wise White, American Chemistry Council (ACC)
Formaldehyde Toxic Substances Control Act (TSCA) Risk Evaluation Consortium regarding
completion of surveillance testing of consumer products for formaldehyde emissions. Available
online at https://www.reeiilations.eov/comment/EPA.-HQ-OPPT-2018-0438-0018
t OM. (2011'). [Redacted] Industrial hygiene air sampling XXX, formaldehyde, XXX.
Ahfa. IN. (2024). Comment submitted by American Home Furnishings Alliance (AHFA), International
Wood Products Association (IWPA), and National Retail Federation (NRF): Formaldehyde
(Docket Number EPA-HQ-OPPT-2023-0613) [Public Comment],
https://www.reeiilations.eov/comment/EPA-HQ-OPPT-2023-0613-0270
. Comment submitted by David Hyde, Director, Environmental Policy, Aerospace Industries
Association (AIA) regarding formaldehyde uses in aerospace. (EPA-HQ-OPPT-2018-043 8-
0006). Arlington, VA. https://www.reeiilations.eov/comment/EPA-HQ-OPPT-2018-0438-0006
(2024). Comment submitted by Aerospace Industries Association (AIA): Formaldehyde (Docket
Number EPA-HQ-OPPT-2023-0613) [Public Comment],
https://www.reeulations.eov/comment/EPA-HQ-OPPT-2023-(
Aim ague i 1 > Mum man i 1 VI; Hurrell. JJ. (1995). Health hazard evaluation report HETA 93-
0154-2527, Truman State Office Building, Jefferson City, Missouri. (HETA 93-0154-2527).
Cincinnatti, OH: National Institute of Occupational Safety and Health.
Almaeuer. D; Boiano. JM. (1986). Health Hazard Evaluation Report HETA-1985-0018-1759 American
Crystal Sugar Company, Moorhead, Minnesota. (HETA 1985-0018-1759). Cincinnati, OH:
Department of Health and Human Services, Centers for Disease Control and Prevention,
National Institute for Occupational Safety and Health.
https://www.cdc.eov/niosh/hhe/reports/pdfs/ If
American Foundry Society. (2024). Comment submitted by American Foundry Society (AFS):
Formaldehyde (Docket Number EPA-HQ-OPPT-2023-0613) [Public Comment],
https://www.reeiilations.eov/comment/EPA-HQ-OPPT-2023-0613-0234
Analvtica. (1 Choosing an appropriate distribution. Available online at
http://wiki.analytica.com/Choosine an appropriate distribution (accessed November 9, 2022).
Analytics Corporation. (2016a). [Redacted] Formaldehyde monitoring results - Fall 2016 (memo dated
11/17/16). (FALL 2016 FA MONITOR). Toledo, OH: Perstorp Polyols.
Analytics Corporation. (2016b). [Redacted] Formaldehyde monitoring results - Spring 2016 (memo
dated 05/27/16). (SPRING 2016 FA MONIT). Toledo, OH: Perstorp Polyols.
Analytics Corporation. (2017a). [Redacted] Formaldehyde monitoring results - Fall 2017 (memo dated
11/13/17). (FA MONITORING). Toledo, OH: Perstorp Polyols.
Analytics Corporation. (2017b). [Redacted] Formaldehyde monitoring results - Spring 2017 (memo
dated 08/23/2017). (Spring 2017 - FAMONI). Toledo, OH: Perstorp Polyols.
Analytics Corporation. (2018a). [Redacted] Formaldehyde monitoring results - Fall 2018 (memo dated
11/06/18). (FA MONITOR FALL 2018). Toledo, OH: Perstorp Polyols.
Analytics Corporation. (2018b). [Redacted] Formaldehyde monitoring results - Spring 2018 (memo
dated 06/15/18). (FAMON - Spring 2018). Toledo, OH: Perstorp Polyols.
Analytics Corporation. (2019a). [Redacted] Formaldehyde monitoring results - Fall 2019 (memo dated
11/11/19). (FA MONITOR FALL 19). Toledo, OH: Perstorp Polyols.
Analytics Corporation. (2019b). [Redacted] Formaldehyde monitoring results - Spring 2019 (memo
dated 06/20/19). (FA MONITOR - Spring 19). Toledo, OH: Perstorp Polyols.
Page 156 of 313
-------
Analytics Corporation. (2020a). [Redacted] Formaldehyde monitoring results - Fall 2020 (memo dated
10/30/20). (FALL 2020 FA MONITOR). Toledo, OH: Perstorp Polyols.
Analytics Corporation. (2020b). [Redacted] Formaldehyde monitoring results - Spring 2020 (memo
dated 06/26/20). (KA MONITORING). Toledo, OH: Perstorp Polyols.
Analytics Corporation. (2021). [Redacted] Formaldehyde monitoring results - Spring 2021 (memo dated
5/28/2021). (SPRING 2021 FA). Toledo, OH: Perstorp Polyols.
Apol obum. TW. (1986). Health Hazard Evaluation Report HETA-1985-462-1748 Boise
Cascade, Vancouver, Washington. (HETA 1985-462-1748). Cincinnati, OH: Department of
Health and Human Services, Centers for Disease Control and Prevention, National Institute for
Occupational Safety and Health, https://www.cdc.eov/niosh/hhe/reports/pdfs pdf
Apol. AG; Okawa. Health Hazard Evaluation Determination, Report No. HHE-76-55-443,
Certain-Teed Products, Inc., Tacoma, Washington (pp. 76-55). (Report No. HHE-76-55-443).
Cincinnati, OH: National Institute for Occupational Safety and Health.
AR1V . Comment submitted by Reed B. Hitchcock, Executive Vice President, Asphalt Roofing
Manufacturers Association (ARMA) regarding initiation of prioritization of formaldehyde under
the Toxic Substances Control Act. Available online at
https://www.reeiilations.eov/comment/EPA-HQ-OPPT-2018-0438-0005
\nn strong. RW: Rood. Ml; Sani. S: Moham » V 1 . {hid. M; Jab \< 1 jndsbereer. S. (2001).
Aerosol particle and organic vapor concentrations at industrial work sites in Malaysia. Asia Pac J
Public Health 13: 24-29. http://dx.doi.on »
\i.k »td. F; En eel \i ;2001). Evaporation of pure liquids from open surfaces. In JBHJ Linders (Ed.),
Modelling of Environmental Chemical Exposure and Risk (pp. 61-71). The Netherlands: Kluwer
Academic Publishers, http://dx.doi.ore/10.1007/978 384-6 6
324). Comment submitted by The Adhesive and Sealant Council: Formaldehyde (Docket
Number EPA-HQ-OPPT-2023-0613) [Public Comment],
https://www.reeiilations.eov/comment/EPA-HQ-OI 23-0613-0249
Aseca. (2024). FAQ: How much land do I need to build a golf course? [Website], https://aseca.org/faq-
how-much-land-do-i-need-to-build-a-eolf-
course/#:~:text=%E2%80%9CThis%20means%2Qan%2Q18%2Dhole.would%20need% '4
)0%20acres.
Asphalt Roofing Manufacturers Association. (2024). Comment submitted by Asphalt Roofing
Manufacturers Association (ARMA): Formaldehyde (Docket Number EPA-HQ-OPPT-2023-
0613) [Public Comment], https://www.regulations.gov/comment/EPA-HQ-QPPT-2023-0613-
0241
Baiai '02). Finishing of textile materials. J Appl Polymer Sci 83: 63 1 -659.
http://dx.doi.oo 02/app.2262
Baldwin. PE; Mayn 8). A survey of wind speed in indoor workplaces. Ann Occup Hyg 42:
303-313. httt; doi.org/10.1016/80003-4878(98)000 I '<
Barsan. ME. (1994). Health hazard evaluation report No. HETA-92-01 17-2388, Rubbermaid, Inc.,
Reynolds, Indiana (pp. 92-0117). (HETA-92-0117-2388). National Institute for Occupational
Safety and Health.
Bassie. BA; Zhang. L; Vermeulen. R; Tang. X; Li. G; H.u. W. ei; Guo. W; Purdue. MP; Yin. S:
Rappaport. SM; Shen. U m h iHu t ^ \ i u^ good. HP; Reir <1' \\ u
-------
Bendix Con BCME formation and detection in selected work environments. Cincinnati, OH:
National Institute for Occupational Safety and Health.
https://ntrl.ntis.gov/NTK3 ;her. R; Nourian. F; Gone. W. ei; Broadwater. K.
(2016). Occupational exposures to new dry cleaning solvents: High-flashpoint hydrocarbons and
butylal. J Occup Environ Hyg 13: 759-769. http://dx.doi.ore/10.1080/15459624.
Celanese Corp. (2020). Comment submitted by Stephanie Daigle, Vice President, Government Affairs,
Celanese Corporation regarding the draft scope of the risk evaluation for formaldehyde.
Available online at https://www.regulations.gov/comment/ '.Q-OPPT-2018-0438-0047
Celanese Corp. (2022). Comment submitted by Celanese Corporation regarding characterization of
occupational exposures during formaldehyde manufacturing, use as an intermediate, and
compounding of formaldehyde-based polymers. Irving, TX.
https://www.reeiilations.eov/comment/EPA-HQ-OPPT-2018-0438-0080
CHEMetrics Safety Data Sheet (SDS): Chlorine CHEMets and ULR CHEMets refills. (R2505).
Midland, VA.
Page 158 of 313
-------
Cherrie. JW: Semple. S; Brouwer. 04). Gloves and Dermal Exposure to Chemicals: Proposals for
Evaluating Workplace Effectiveness. Ann Occup Hyg 48: 607-615.
http://dx.doi.oo 93/annhyg/meh060
Chrostek Health hazard evaluation report: HETA-84-392-1597 - Syntex Dental Products,
Inc., Audubon, Pennsylvania. (NIOSH/00153676; HETA-84-392-1597). Cincinnati, OH:
National Institute for Occupational Safety and Health.
https://www.cdc.eov/niosh/hhe/reports/pdfs/84-392-1597.pdf
CI ere iinhausen. M: Bertrand. N: Vincent. R; Gabriel. S: Van Gelder. R. (2015). Comparison of
formaldehyde exposure measurements stored in French and German databases. Gefahrst Reinhalt
Luft 75: 119-126.
Colgate-Palmolive Com pa 16a). Softsoap liquid hand soap aloe vera. Available online at
https://www.whatsinproducts.eom//brands/show rosds/ (accessed January 7, 2020).
Colgate-Palmolive Com pa 16b). Suavitel fabric softener liquid morning sun. Available online at
https://www.whatsinprodiicts.eom//brands/show msds/1/16979 (accessed January 7, 2020).
Cook. CK; Page. EH. (2000). Health hazard evaluation report, HETA 99-0137-2810: World Color
Press, Effingham, Illinois, September 2000. (HETA 99-0137-2810). Cincinnati, OH: National
Institute for Occupational Safety and Health.
Comwell. R (1988). Health Hazard Evaluation Report HETA 88-230-1939, Morgan Shirt Company,
Morgantown, West Virginia, December 1988. (HETA #88-230-1939). Cincinnati, OH:
Department of Health and Human Services, Centers for Disease Control and Prevention,
National Institute for Occupational Safety and Health.
https://www.cdc.gov/niosh/hhe/reports/pdfs/1988-023Q-1939.pdf
Costa. S: Carvalho. S: Costa. C; Coelho. P; Silva. S: Santos. LS; Gasp to. B; Laffon. B;
Teixeira. IP. (2015). Increased levels of chromosomal aberrations and DNA damage in a group
of workers exposed to formaldehyde. Mutagenesis 30: 463-473.
http://dx.doi.oo 93/mutage/gev002
Covestro. (2024). Comment submitted by Covestro LLC: Formaldehyde (Docket Number EPA-HQ-
OPPT-2023-0613) [Public Comment], https://www.regiilations.gov/comment/EPA-
2023-0613-0277
Crete ,s. R; Beaudreau. M; Davis. M. (2010). Emission factors and exposures from ground-
level pyrotechnics. Atmos Environ 44: 3295-3303.
http://dx.doi.oo 10 101 i.atmosenv.,010 00 I\
Cuadros. S: Font J t quierdo. t t uadros. R. osa. M.: 01 le, L; Marsal, A. (2016). Determination of
formaldehyde content in leather: Standard EN ISO 17226 (parts 1 and 2), revision and possible
improvements. Journal of the Society of Leather Technologists and Chemists 100: 167-174.
Daftarian. H.S; Roegner. KC: Reh. CM. (2000). Health hazard evaluation report 98-001 1-2801
Woodbridge Corporation Brodhead, Wisconsin July 2000. (HETA #98-0011-2801). Cincinnati,
OH: National Institute for Occupational Safety and Health.
Davis. ME; Blichar Hart, IE; Laden t arshick. E; Smith. TJ. (2007). Occupational Exposure to
Volatile Organic Compounds and Aldehydes in the U.S. Trucking Industry. Environ Sci Technol
41: 7152-7158. http://dx.doi.org/10.102l/es071041 z
Diberardinis wards. R; Herrick. R; Julien. R. (2001). Strategy to assess exposure of laboratory
personnel to select OSHA-regulated chemicals at Massachusetts Institute of Technology. Chem
Health Saf 8: 25-29. http://dx.doi. 098(01)00215-5
Dow Chemical. (2016). [Redacted] Industrial hygiene assessment of employee exposures to
formaldehyde during manufacturing of Dow Corning® MB40-006 Masterbatch on Line 7 at the
Copley, OH Multibase Site. Midland, MI.
Dow Chemical. (2017a). [Redacted] 2016 Exposure monitoring for XXX at Dow Water Solutions Ion
Exchange-Anion/SR Facility, 963 Building, Midland, MI USA. (42_552). Midland, MI.
Page 159 of 313
-------
Dow Chemical. (2017b). [Redacted] 2016 Exposure monitoring for XXX formaldehyde, XXX at the
Michigan Operations Environmental Operations Facility, Midland, MI, USA. (42 579).
Midland, MI.
Dow Chemical (2017c). [Redacted] 2017 Personal exposure monitoring for XXX formaldehyde, XXX
at the Elk Grove Site, Elk Grove Village, Illinois, USA. (312 76). Midland, MI.
Dow Chemical. (2017d). [Redacted] Industrial hygiene assessment of employee exposures to
formaldehyde during manufacturing of Dow Corning® IT MQ-1644H Solid Resin in MOD B
2901 Building Dow Corning Midland Plant, Midland MI. (2017-10000-79734). Midland, MI.
Dow Chemical. (2019a). [Redacted] 2018: Personal monitoring for formaldehyde, XXX at the
Anion/SR Plant in Ion Exchange Midland, MI USA. (42_512). Midland, MI.
Dow Chemical. (2019b). [Redacted] 2018: Summary of industrial hygiene monitoring for oxide.
(88_630). Midland, MI.
Dow Chemical. (2019c). [Redacted] Personal IH monitoring for XXX formaldehyde, XXX at the HT
Facility in Deer Park, Texas from April 25, 2016 to September 19, 2018. (304_135). Midland,
MI.
Dow Chemical. (2024). Comment submitted by Dow Chemical: Formaldehyde (Docket Number EPA-
HQ-OPPT-2023-0613) [Public Comment], https://www.regulations.gov/comment/EPA-HQ-
OPPT-2023 -0613 -0269
Dunky. M. (2004). Adhesives based on formaldehyde condensation resins. Macromol Symp 217: 417-
429. http: //dx. doi. or g/10.1002/m asv. ^
Dunn 1 *\\ it'boson. ML; Hectic W K l\u^ r^u^ti GJ; Mckinnerv. WN. (1983a). Reducing plant
pollution exposure - Control practices at formaldehyde production plants. Chemical Engineering
Progress 79: 35-38.
Dunn \\ l'0E.pdf
Worker exposure to formaldehyde and formaldehyde releasers. Helsinki, Finland.
Health Hazard Evaluation Report HETA 93-0028-2366, West Helena - Helena
Sportswear, Inc., West Helena, Arkansas. (HETA 93-0028-2366). Echt, A.
https://www.cdc.gov/niosh/hhe/reports/pdfs/1993-0028-2366.pdf
EPF. (2019). Comment submitted by Robert Stockman, Senior Attorney, Environmental Defense Fund
(EDF) regarding proposed high-priority substance designations under the Toxic Substance
Control Act (TSCA). (EPA-HQ-OPPT-2018-043 8-0017). New Yrok, NY.
https://www.regiilations.gov/dociiment/EPA-HQ-OPPT-2018-0438-0017
Elmer's. (2012). (M)SDS For: Elmer's CraftBond Acid-Free Multi-Purpose Spray Adhesive, Aerosol.
Available online at https://www.whatsinproducts.eom//brands/show msds/1/ (accessed
January 7, 2020).
Enviro Control Inc. (1983). Industrial hygiene characterization of urea formaldehyde and polyurethane
foam insulation. (DHHS (NIOSH) Publication Number 83-108). Cincinnati, OH: National
Institute for Occupational Safety and Health, https://www.cdc.gov/niosh/docs/83-108/
Fehrenbacher. MC: Humm Evaluation of the Mass Balance Model Used by the EPA for
Estimating Inhalation Exposure to New Chemical Substances. Am Ind Hyg Assoc J 57: 526-536.
Ftari; ngh. G; Rao. AR. (2009). Recycling electronic waste. Plast Eng 65: 10-15.
http://dx.doi ?635.2009.tb00452.x
Page 160 of 313
-------
Fran smart W; Mcleon H, Houwes J, Homers. P 1 oung. V; Pearce. N. (2003). Respiratory symptoms
and occupational exposures in New Zealand plywood mill workers. Ann Occup Hyg 47: 287-
295. http://dx.doi.ore/10.1093/aimhye/mee046
FRM Risk. ( . [Redacted] Industrial hygiene air contaminant assessment report.
FWIC. (2020). Comments of the Federal Wood Industries Coalition regarding the draft scope of the risk
evaluation for formaldehyde (comment submitted by Jackson Morrill). Available online at
https://www.reeiilations.eov/comment/EPA-HQ-OPPT-2018-0438-0037
Garbassi R (2001). Engineering thermoplastics. In Kirk-Othmer Encyclopedia of Chemical
Technology. Hoboken, NJ: John Wiley & Sons, Inc.
http://dx.doi.on tOkWvM i. 8961.0514070903120107.aO 1 ,pub2
Geivanidis. S; Pistikopoulos. P; Samaras. Z. (2003). Effect on exhaust emissions by the use of
methylcyclopentadienyl manganese tricarbonyl (MMT) fuel additive and other lead replacement
gasolines. Sci Total Environ 305: 129-141. http://dx.doi.ore/10.1016/80048-9697(02)00 I \
Georeia-Pac psum. (2024). Comment submitted by Georgia-Pacific Gypsum LLC: Formaldehyde
(Docket Number EPA-HQ-OPPT-2023-0613) [Public Comment],
https://www.reeulations.eov/comment/EPA-HQ-OPPT-2023-(
Gerberich. HR; Seamai Formaldehyde. In JI Kroshwitz; M Howe-Grant (Eds.), Kirk-
Othmer encyclopedia of chemical technology (4th ed., pp. 929-951). New York, NY: John Wiley
& Sons.
Gock'H i t lorstman. SW: Scott. CS I ; l 31}. Formaldehyde emissions from carbonless copy paper
forms. Am Ind Hyg Assoc J 42: 474-476. http://dx.doi.ore/10 10N0/1529866N I •} I IJ0099
God? }. Laboratory safety: Minimizing the toxic effects of formaldehyde.
Lab Med 29: 39-42. http://dx.doi.ore/10.1093/labmed/29.1.39
Greeson. HK. Jr: Brownine. KJ; Farrell. ID. (2012). Formaldehyde reduction for durable press cotton
fabrics. AATCC Rev 13: 36-40.
Gunt Health Hazard Evaluation Report No. 77-37-413, Gates Rubber Company, Denver,
Colorado. (HHE 77-37-413). Cincinnati, OH: National Institute for Occupational Safety and
Health, https://www.cdc.eov/niosh/hhe/reports/pdfs f
GWPC and IOGCC. (2022). FracFocus: Chemical disclosure registry [Database], Retrieved from
https://fracfocus.org/data-download
Hall. RM; Bern;u>t H, iLtrnev. J: McCleery. R; Gillen. M; Hess. JE; Kiefer. M; Mattorano. D: Delanev.
:ead. K. (2002). Health Hazard Evaluation Report 2002-0136, United Stated Senate and
House of Representatives, Washington, D.C., July 2002. (HETA #2002-0136-2880). Cincinnati,
OH: Department of Health and Human Services, Centers for Disease Control and Prevention,
National Institute for Occupational Safety and Health.
https://www.cdc.eov/niosh/hhe/reports/pdfs/20C 80.pdf
Harlev. KG; Calderon. L; Nolan. JES; Maddalena. R; Russell. M; Roman. K; Mayo-Bureos. S: Cabrera.
J: Morga. N: Bradman. A. (2021). Changes in Latina women's exposure to cleaning chemicals
associated with switching from conventional to "green" household cleaning products: The
LUCIR intervention study. Environ Health Perspect 129: 97001.
http://dx.doi.oo 89/EHP8831
Heitbrink. W: Coop-n i «l
-------
Ho. SSH: Ip. H.SS; Ho. UA ^ J M i ui. WT; Cao. J; Chan. CS; Ho. LB. (2014). Evaluation of
hazardous airborne carbonyls on a university campus in southern China. J Air Waste Manag
Assoc 64: 903-916. http://dx.dot.( 3/10962247.2014.903214
Hosgiwt UH lU j^hang. L; Tang. X; Vermeulen. R; Hao. Z; Shen. M. in; ^ t. ti. M; Ji. Z;
Li. S; Xiong. J. un; Reiss. B; Liu. S; Xin. KX; Azuma. \t^ \ i iceman. J Kuan. X; Guo.
W; Gal van. N. oe; Blah \ It 1 Uaang. H; Smith. MT; Rothman. N; Lan. O. (2013).
Occupational exposure to formaldehyde and alterations in lymphocyte subsets. Am J Ind Med
56: 252-257. http://dx.doi.org/i 0. i 002/aittn.22088
Hovding Free formaldehyde in textiles. A cause of contact eczema. Acta Derm Venereol 39:
357-368.
Hovding Contact eczema due to formaldehyde in resin finished textiles. Acta Derm Venereol
41: 194-200.
IARC. (1982). IARC monographs on the evaluation of the carcinogenic risk of chemicals to humans:
Some industrial chemicals and dyestuffs (pp. 1-398). Lyon, France: International Agency for
Research on Cancer :: IARC. http://monographs.iarc.fr/ENG/Monographs/vol29/voliime29.pdf
K ?84). Formaldehyde emissions from building products: cost-effectiveness of reduction
strategies. Chapter II: formaldehyde-emitting wood products and alternatives for controlling
emissions [TSCA Submission], (OTS0524645. 40-84021993. 44004 B1C-1. TSCATS/409186).
EPA.
loras. F; Mc atthondan. V: Ratnasingam. J. (2010). Dust, noise and chemical solvents
exposure of workers in the wooden furniture industry in South East Asia. Journal of Applied
Sciences 10: 1413-1420. http://dx.doi.Org/10.3923/ias.2 0
IPC International. ( . IPC presentation to EPA on formaldehyde in the electroless copper plating
process. Presentation presented at Meeting with IPC and EPA to discuss conditions of use for
formaldehyde, Washington, DC.
IPC International. (2020). Comment submitted by Kelly Scanlon, Director of Environment, Health and
Safety Policy and Research, IPC regarding the draft scope of the risk evaluation for
formaldehyde. Available online at https://www.regulations.gov/comment/EPA-HQ-OPPT-2Q18-
0438-0050
Jahromi. WHBMDS. (2005). Melamine resins. In Kirk-Othmer Encyclopedia of Chemical Technology.
New York, NY: John Wiley & Sons.
https://onlinelibrarY.wiley.com/doi/abs/10.1002/ 51.melabind.a01
Kilburn. KH; Seidman. BC: Warshaw. R. (1985). Neurobehavioral and respiratory symptoms of
formaldehyde and xylene exposure in histology technicians. Arch Environ Occup Health 40:
229-233. http://dx.doi.tnv h"0/00039896.1 ?stO-45924
Kim. S. (2010). Control of formaldehyde and TVOC emission from wood-based flooring composites at
various manufacturing processes by surface finishing. J Hazard Mater 176: 14-19.
http://dx.doi.org/10 J 016/i j hazmat.2(Avs 0 '< I l'<
Kinnes. GM. (1990). Health hazard evaluation report: HETA-88-279-2026, Kardon Industries, St. Paris,
Ohio. (HETA 88-279-2026). Cinncinati, OH: U.S. Department of Health and Human Services,
Public Health Service, Centers for Disease Control, National Institute for Occupational Safety
and Health, https://www.cdc.gov/niosh/hhe/reports/pdfs/1988-0279~2026.pdf
Kinnes. GM; Mortimer Health hazard evaluation report, HETA 97-0106-2770: Sommer-
Allibert Industries, USA, Inc., Kansas City, Missouri, December 1999. (HETA #97-0106-2770).
Cincinnati, OH: National Institute for Occupational Safety and Health.
Kitwattanavong. M; Pmeksasii I' Morknoy. D; Tunsaringkarn I v iriwong. W. (2013). Health risk
assessment of petrol station workers in the inner city of Bangkok, Thailand, to the exposure to
BTEX and carbonyl compounds by inhalation. Hum Ecol Risk Assess 19: 1424-1439.
http://dx.doi.on 80/10807039.2012.685814
Page 162 of 313
-------
Klincewicz. SL; Reh. CM. (1989). Health hazard evaluation report: HETA-87-411-1972, Naval
Weapons Support Center, Crane, Indiana. (HETA 87-411-1972). Cinncinati, OH: U.S.
Department of Health and Human Services, Public Health Service, Centers for Disease Control,
National Institute for Occupational Safety and Health.
https://www.cdc.eov/niosh/hhe/reports/pdfs/198 72.pdf
Koch Tu Nitroform Slow-Release Urea-Formaldehyde (UF) fertilizer. Wichita, KS.
Kominskv. 1R; Stromal Health Hazard Evaluation Determination, Report No. HHE-77-15-
421, Leed and Northrup Corporation, Expendable Devices Division Ellwood City, Pennsylvania
(pp. 77-15). (NIOSH/00074930). Kominsky, JR; Stroman, RE.
https://www.cdc.eov/niosh/hhe/reports/pdfs/ ;
Krali. AAK. (2015). The re-usages of wastewater within industry: the positive impact of contaminants. J
Clean Prod 95: 124-130. http://dx.doi.ore/10.1016/i idepro.2015.02.054
Kullman. GJ. (1989). Health Hazard Evaluation Report HETA 88-269-1993, Meyersdale Manufacturing
Co., Meyersdale, Pennsylvania, October 1989. (HETA 88-269-1993). Cincinnati, OH:
Department of Health and Human Services, Centers for Disease Control and Prevention,
National Institute for Occupational Safety and Health.
https://www.cdc.eov/niosh/hhe/reports/pdfs/1988-0269-1993.pdf
LaDc )}. Printed circuit board industry [Review], Int J Hyg Environ Health 209: 21 1-219.
http://dx.doi.oo .iiheh.2006.02.001
Lav one. J; Beau » vyer. N; Perrauh -erin. M. (2005). Investigation of determinants of past
and current exposures to formaldehyde in the reconstituted wood panel industry in Quebec. Ann
Occup Hyg 49: 587-602. http://dx.doi.ore/10.1093/annhve/me
Lebkowska. M; Narozniak-Rutkowska. A; Paior. E. (2013). Effect of a static magnetic field of 7 mT on
formaldehyde biodegradation in industrial wastewater from urea-formaldehyde resin production
by activated sludge. Bioresour Technol 132: 78-83.
http://dx.doi.ore/10.1016/i .biortech.201 '< 01 0.0
Jeone. S: Yi. GY; Shin. J. (2012). Work environments and exposure to hazardous
substances in Korean tire manufacturing. Saf Health Work 3: 130-139.
http://dx.doi.on SHAW.2012.3.2.130
Lee. SA. (1988). Health Hazard Evaluation Report HETA 87-309-1906, Louisiana-Pacific Corporation,
Missoula, Montana, June 1988. (HETA #87-309-1906). Cincinnati, OH: Department of Health
and Human Services, Centers for Disease Control and Prevention, National Institute for
Occupational Safety and Health, https://www.cdc.gov/niosh/hhe/reports/pdfs/1987-0309-
1906.pdf
Health Hazard Evaluation Report: HHE-2016-0145-3292, October 2017. Evaluation of
employee exposures at a plastic bag sealing plant. (2016-0145-3292). Cincinnati, OH: NIOSH.
Lin. D; Guo. Y; Yi. J; Ktiai^ * * an: Li. X; Dene. H; Huang. K. un; Guan. L. ei; He. \ bane. X: H.u.
D. ie: Zhang ' 'bene. H; Zhang. X: Mchale. CM: Zhang. L; Wti. T. (2013). Occupational
exposure to formaldehyde and genetic damage in the peripheral blood lymphocytes of plywood
workers. J Occup Health 55: 284-291. http://dx.doi.ore/10.1539/joli IJ 0288 • * \
Lofstedt. H: Westbere. H: S el den. ;etsson. IL: Svartengren. M. (2011a). Respiratory symptoms
and lung function in foundry workers using the hot box method: A 4-year follow-up. J Occup
Environ Med 53: 1425-1429. http://dx.doi.oiv 10 10^ K >M.0b0l ^ < INi363cl7
Lofstedt. H: Westberg. H: S el den. mdholm. C: Svartengren. M. (2009). Respiratory symptoms and
lung function in foundry workers exposed to low molecular weight isocyanates. Am J Ind Med
52: 455-463. http://dx.doi.ore/10.1002/aiim.20693
Lofstedt. H: Westbere. H: S el den. AI: Rudbl leelsson. IL: Ngo. Y: Svarteneren. M. (2011b).
Nasal and ocular effects in foundry workers using the hot box method. J Occup Environ Med 53:
43-48. hut; »ivdoi.ore/10.1097/JQM.0b01 ^ '«I s I \ I f iO v c
Page 163 of 313
-------
Lyapina. M; Zhelezova trova. E; Boev. M. (2004). Flow cytometric determination of neutrophil
respiratory burst activity in workers exposed to formaldehyde. Int Arch Occup Environ Health
77: 335-340. http://dx.doi.org/i 0 J 007/s00420-004-0 -1 '<
Maiumdar (nee som). D; Dutta. C; Mukh t S. (2008). Source apportionment of VOCs at
the petrol pumps in Kolkata, India; exposure of workers and assessment of associated health risk.
Transport Res Transport Environ 13: 524-530. http://dx.doi.org/10.1016/i .trd.20QS 0° 01 I
Makinen. M; Kalliokoski. P; Kan gas. *9). Assessment of total exposure to phenol-formaldehyde
resin glue in plywood manufacturing. Int Arch Occup Environ Health 72: 309-314.
http://dx.doi.on >004200050380
Marl Health hazard evaluation report HETA 94-0309-2514, Homecrest Industries
Incorporated, Wadena, Minnesota. (HETA 94-0309-2514). Cincinnati, OH: National Institute for
Occupational Safety and Health.
Marquart. H; Franken. R; Goede. H; Fransman. W; Schinkel. J. (2017). Validation of the dermal
exposure model in ECETOC TRA. Ann Work Expo Health 61: 854-871.
http://dx.doi.oo 93/annweh/wxx059
Material Research. (2019). Formaldehyde: Technical report on the conditions of use. Washington, DC:
Earthjustice. https://www.regulations.gov/comment/EPA-HQ-OPPT-2018-0438-0018
Mauer. MP; Cook. CK. (1999). Health hazard evaluation report HETA 97-0242-2725, Delphi Chassis
Systems, Dayton, Ohio, February 1999. (HETA #97-0242-2725). Cincinnati, OH: National
Institute for Occupational Safety and Health.
McCammon I. Health hazard evaluation report 97-0138-2677 Shindoni, Inc. Tesuque, New
Mexico February 1998. (HETA #97-0138-2677). Cincinnati, OH: National Institute for
Occupational Safety and Health.
Methner. MM; Tapp. L; Rams-n i ^01 11 Health Hazard Evaluation Report: HETA-2012-0025-3207,
May 2014. Evaluation of Metals, Solvents, Formaldehyde, Ventilation, and Ergonomic Risks
During the Manufacture of Electrical Cable Accessories. (NTIS/11820040_a). Methner, MM;
Tapp, L; Ramsey, J.
Minitab. (2022). A comparison of the Pearson and Spearman correlation methods. Available online at
https://siipport.minitab.com/en-iis/minitab/21/help-and-how4o/statistics/basic-
statistics/supporting-topics/correlation-and-covariance/a-comparison-of-the-pearson-and-
spearman-correlation-methods/ (accessed November 9, 2022).
Mirabelli. MC; Holt. SM; Cope. JM. (2011). Anatomy laboratory instruction and occupational exposure
to formaldehyde. Occup Environ Med 68: 375-378. http://dx.doi.org/) 0 I I '< )/oem.2010 0\'V« V
Moezziptmi \hdolkhani \ li. Doost-Hoseini. K; Ramazaw * \\ • ian. A. (2018). Practical
properties and formaldehyde emission of medium density fiberboards (MDFs) recycled by
electrical method. Holz als Roh- und Werkstoff 76: 1287-1294.
http://dx.doi.on 10 100 >>0010 OiS t: I .
Monsanto Research Cc 81). Preliminary plant visit industrial hygiene report: Formaldehyde
production facility, Monsanto Plastics and Resins Company, Eugene, Oregon. (114-22a).
Cincinnati, OH: U.S. Environmental Protection Agency.
https://www.cdc.gOv/niosh/siirveyreports/pdfs/l 14-22a.pdf
Monsanto Research Cc 83). Detailed industrial hygiene survey: formaldehyde production,
Georgia-Pacific Corporation, Albany, Oregon. (114-15b). Cincinnati, OH: U.S. Environmental
Protection Agency. https://www.cdc.gov/niosh/survevreports/pdfs
NAD 319). Comment submitted by Angus E. Crane, Executive Vice President, General Counsel,
North American Insulation Manufacturers Association (NAIMA) regarding initiation of
prioritization under the Toxic Substances Control Act. Available online at
https://www.regiilations.gov/comment/EPA-HQ-OPPT-2018-0438-0008
Page 164 of 313
-------
NASA. (2020). Comment submitted by Denise Thaller, Director, Environmental Management Division,
National Aeronautics and Space Administration (NASA) regarding draft scopes of the risk
evaluations to be conducted for seven chemical substances under the Toxic Substance Control
Act (TSCA). (EPA-HQ-OPPT-2018-0438-0057). Washington, DC.
https://www.reeiilations.eov/dociiment/EPA-HQ-OPPT-2018-0438-0Q57
NICNAS. (2006). Priority existing chemical assessment report no. 28: Formaldehyde (pp. 121-143).
Sydney, Australia: Australian Government Department of Health, National Industrial Chemicals
Notification and Assessment Scheme.
https://www.indiistrialchemicals.eov.aii/sites/defaiilt/files/PEC28-Formaldehyde.pdf
NIOE Health hazard evaluation: Gates Rubber Company. (Report No. 72-86).
NIOE Health hazard evaluation determination: Osborne Photographic Laboratories, Inc.
(Report no. 73-191-149).
NKK ). Survey of Burlington Industries, Inc., Burlington House Finishing Plant, Form Fabrics
Plant, Durham Domestics Plant, Brookneal Finishing Plant. (IWS-33.18). Cincinnati, OH.
https://ntrl.ntis.eov/NTK( l Mb). Health hazard evaluation report: HHE 80-103-827. Joel & Aronoff, Ridgefield, NJ.
(HHE 80-103-827). Washington, DC: Center for Disease Control.
https://www.cdc.eov/niosh/hhe/reports/pdfs/80-103-827.pdf
NKK U ^ rs8 ic). Health hazard evaluation report: HHE 80-192-828. Rock Hill Printing and Finishing
Company, Rock Hill, NC. (HHE 80-192-828). Washington, DC: Center for Disease Control.
https://www.cdc.eov/niosh/hhe/reports/pdfs/80-192-828.pdf
NKK 8Id). Walk-Through Survey Report: Monsanto Plastics and Resins Company,
Phenolormaldehyde Resin Facility, Port Plastics Plant, River Road, Addyston, Ohio, Report No.
CT-108-lla (pp. 108-111). (NIOSH/00183681). Mortimer VD Jr.
NKK 82a). Health hazard evaluation report: HETA-80-144-1 109. Film Processing Industry,
Hollywood, California (pp. 1-34). (NIOSH/00127502). Washington, DC: Center for Disease
Control. https://www. cdc.gov/niosh/hhe/reports/pdfs/8( f
NKK 82b). Health hazard evaluation report: HETA-82-264-1232. Olympic Medal Laboratories,
Bremerton, Washington (pp. 1-10). (NIOSH/00127577). Washington, DC: Center for Disease
Control. https://www.cdc.eov/niosh/hhe/reports/pdfs/82-264-1232.pdf
NKK 82c). Health hazard evaluation report: HETA 82-342-1223. William Blount High School,
Maryville, TN. (HETA 82-342-1223). Washington, DC: Center for Disease Control.
https://www.cdc.gov/niosh/hhe/reports/pdfs/82-342-1223.pdf
NKK 83a). Health evaluation and technical assistance report: HETA-81 -422-1387. California
Society For Histotechnology, Los Angeles, California (pp. 1-49). (NIOSH/00137474).
Washington, DC: Center for Disease Control. https://www.cdc.gov/niosh/hhe/reports/pdfs/1981-
0422-1387.pdf
NKK Health hazard evaluation report: HETA-82-349-1332. Wool rich Woolen Mills, Inc.,
Woolrich, Pennsylvania (pp. 82-349). (NIOSH/00133466). Washington, DC: Center for Disease
Control. https://www.cdc.eov/niosh/hhe/reports/pdfs/82-349-1332.pdf
NKK 84a). Health hazard evaluation report: HETA-83-301 -1478. Lion Uniform Company,
Beattyville, Kentucky (pp. 1-26). (HETA 83-301-1478). Cincinnati, Ohio: U.S. Department of
Health and Human Services, https://www.cdc.gov/niosh/hhe/reports/pdfs/83-
Page 165 of 313
-------
NIOE 84b). Health hazard evaluation report: HETA-84-065-1519. Southern Oregon State College,
Ashland, OR. (HETA 84-065-1519). Washington, DC: Center for Disease Control.
https://www.cdc.eov/niosh/hhe/reports/pdfs/ if
NIOE 86). Current intelligence bulletin: Reprints - Bulletins 3 1 thru 47. (DHHS (N10SH)
Publication Number 86-122). Cincinnati, OH: Center for Disease Control and Prevention.
https://www.cdc.eov/niosh/docs/86-122/
NIOE Health hazard evaluation report no. HETA-92-092-2333, General Castings Power
Street facility, Cincinnati, Ohio. (HETA-92-092-2333).
NIOSH. (1998). Health Hazard Evaluation Report HETA 97-0154-2693, Siemens Energy and
Automation, Inc., Distribution Products Division, Urbana, Ohio. (HETA-97-0154-2693;
HETA9701542693). Cincinnati, OH. Div. of Surveillance, Hazard Evaluations and Field Studies.
: National Institute for Occupational Safety and Health.
NIOE 00). NIOSH Hazard Review: Carbonless copy paper. (DHHS (NIOSH) Publication No.
2001-107). Atlanta, GA: Center for Disease Control and Prevention.
NIOSH. (2003a). Niosh health hazard evaluation report- Bemis. (HETA 2003-0102-2921).
NIOSH. (2003b). Respirator Usage in Private Sector Firms. Washington D.C.: United States Department
of Labor, Bureau of Labor Statistics and National Institute for Occupational Safety and Health.
https://www.cdc.eov/niosh/docs/respsurv/
NIOE Evaluation of potential employee exposures during crime and death investigations at a
county coroner's office. (Report No. 2011-0146-3170). Washington, DC: U.S. Department of
Health and Human Services, Centers for Disease Control and Prevention, National Institute of
Occupational Safety and Health, http://www.cdc.eov/niosh/hhe/reports/pdfs/
Norback. D; Wieslandei u,i 'dltitv t > r^5). Occupational exposure to volatile organic compounds
(VOCs), and other air pollutants from the indoor application of water-based paints. Ann Occup
Hyg 39: 783-794. http://dx.doi.or: 0003-4878(95)00034-8
NTP. (2010). Final report on carcinogens. Background document for formaldehyde [NTP] (pp. i-5 12).
NZ DO! Review of occupational health problems associated with formaldehyde exposure (26)
[TSCA Submission], (OTS0507047. 44004 B2-9. TSCATS/034013).
Oberle. W. (2015). Monte Carlo simulations: Number of iterations and accuracy. (ARL-TN-0684).
Aberdeen Proving Ground, MD: US Army Research Laboratory.
https://apps.dtic.mil/sti/pd: If
OECD. (2002). S1DS Initial Assessment Report: Formaldehyde (CAS no: 50-00-0) [OECD S1DS],
Paris, France: UNEP Publications, https://hpvchemicals.oecd.ore/ui/handler.axd?id=5525377e-
M L I d04- t >cacfadf8bb
OECD. (2004a). Emission scenario document on leather processing.
http://www.oecd. ore/officialdocuments/publicdisplavdocumentpdf/?cote=env/im/mono(20<
&doclanguage=en
OECD. (2004b). Emission scenario document on lubricants and lubricant additives. In OECD Series On
Emission Scenario Documents. (JT00174617). Paris, France.
http://www.oecd.ore/offi cialdocuments/publicdisplavdocumentpdf/?cote=env/im/mono(2004)21
&doclanguage=en
OECD. (2009a). Emission scenario document on adhesive formulation. (ENV/JM/MONO(2009)3;
JT03263583). Paris, France.
http://www.oecd.ore/officialdocuments/publicdisplavdocumentpdf/?cote=env/im/mono(2009)3&
doclanguage=en
OECD. (2009b). Emission scenario documents on coating industry (paints, lacquers and varnishes).
(JT03267833). Paris, France.
http://www.oecd.ore/officialdocuments/publicdisplavdocumentpdf/?cote=env%20/im/mono(200
9)24& docl an euaee=en
Page 166 of 313
-------
OECD. ( . Emission Scenario Document on Photoresist Use in Semiconductor Manufacturing. In
Series on Emission Scenario Documents No 9. Paris: OECD Environmental Health and Safety
Publications, http://dx.doi.ore/ 10 I S7/9789264 J J I i>- i ^it
OECD. ( . Emission scenario document on coating application via spray-painting in the
automotive refinishing industry. (ENV/JM/MONO(2004)22/REV1). Paris, France: Organization
for Economic Co-operation and Development.
http://www.oecd. org/officialdocuments/publicdisplaydocumentpdf/?cote=env/im/mono(2004)22/
rev 1& docl an guage=en
OECD. ( . Emission Scenario Document on the application of radiation curable coatings, inks, and
adhesives via spray, vacuum, roll, and curtain coating.
OECD. ( . Emission scenario document on the chemicals used in water-based washing operations
at industrial and institutional laundries. (JT03304937). Paris, France, https://www.oecd-
ilibrarv.ore/docserver/9789264220973-
en.pdf?expii^ I a I 50&1 d=id&accname=euest&checksum =B8i I l! ^ I0603EB565B89A
8AE6A24C14
OECD. ( . Emission scenario document on the use of metalworking fluids. In OECD
Environmental health and safety publications Series on emission scenario documents Emission
scenario document on coating and application via spray painting in the automotive refinishing
industry Number 11. (JT03304938). Organization for Economic Cooperation and Development.
OECD. ( . Emission scenario document on chemicals used in oil well production. (JT033 18094).
Paris, France, https://www.oecd-ilibrarv.org/docserver/9789264220966-
en.pdf?expii^ \ - I _ K,:id=id&accname=guest&checksum= T > r ^ iWs 1 t i H \0
0541C9B1F6A
OECD. (2015a). Emission scenario document (ESD) on chemical vapour deposition in the
semiconductor industry. Paris, France: Organisation for Economic Co-operation and
Development, OECD Environment Directorate, Environment, Health and Safety Division.
http://www.oecd. org/officialdocuments/publicdisplaydocumentpdf/?cote=ENV/JM/MONO(2015
) 5 & docl an guage=en
OECD. (2015b). Emission scenario document on use of adhesives. (Number 34). Paris, France.
http://www.oecd. org/officialdocuments/publicdisplavdocumentpdf7?cote=ENV/JM/MQNQ(2015
)4& docl an guage=en
OECD. ( . Emission scenario document (ESD) on the use of textile dyes.
(ENV/JM/MONO(2015)50). Paris, France: OECD, Inter-Organization Programme for the Sound
Management of Chemicals (10MC). http://www.oecd.org/chemicalsafety/risk~
as ses sm ent/em i s si on seen ari odocum ents.htm
OECD. (2020). Emission scenario document on chemical additives used in automotive lubricants. Paris,
France.
Offermai . Formaldehyde emissions from laminate flooring [Editorial], ASHRAE J 59: 102-
105.
Oh. YS: Kim. JM. ( Properties of oriented strandboard bonded with phenol-urea-formaldehyde
resin. J Trop Forest Sci 27: 222-226.
Oliva-Teles. MT; Paiga. P; Delerue-Matos. CM; Alvim-Ferraz. MCM. (2009). Evaluation of
Formaldehyde in Foundry Waste Sands Using Liquid Chromatography. Anal Lett 42: 492-504.
http://dx.doi.on 10 1080/000. IQSQ2363453
OPW Engineered Systems. (2014). Loading Systems Catalog. OPW Engineered Systems: A Dover
Company. ES-LS-6/15-2M; Uploaded November 18, 2014. OPW Engineered Systems.
http://www.opwglobal.com/docs/libraries/sales-literature/chemical-industrial/engineered-
svstems/brochures/opw-es-loading systems cat.pdf?sfVrsn=6
Page 167 of 313
-------
Oracl Selecting probability distributions. In Oracle® Crystal Ball User's Guide; 2017 (Release
11124). Austin, TX. https://docs.oracle.com/cd/^ [/CYBUG/apas03 .html
OSHA. ( . Chemical exposure health data (CEHD) sampling results: CASRNs 75-34-3, 85-68-7,
84-74-2, 78-87-5, 117-81-7, 106-93-4, 50-00-0, 95-50-1, 85-44-9, 106-46-7, 79-00-5, and 115-
86-6. Washington, DC: U.S. Department of Labor. Retrieved from
https://www.osha.eov/openeov/healthsamples.html
OSHA.. (2023). OSHA technical manual: Section II: Chapter 1: Personal sampling for air contaminants.
Washington, DC: U.S. Department of Labor, Occupational Safety and Health Administration,
Office of Training and Education, https://www.osha.eov/otm/section-2-health-hazards/chapter-l
Pala. M; Ueolini. D; Ceppi. M; Rizzo. F; Maiorana. L; Boloenesi. C; Schilirc 111. G: Bieatti. P;
Bono. R; Vecchio. D. (2008). Occupational exposure to formaldehyde and biological monitoring
of Research Institute workers. Cancer Detect Prev 32: 2008.
http://dx.doi.oo .cdp.2008.05.003
Palisade. (2015a). Palisade Knowledge Base: 2.6. How many iterations do I need? Available online at
https://kb.palisade.com/index.php?pe=kb.paee&id=125 (accessed November 9, 2022).
Palisade. (2015b). Palisade Knowledge Base: 2.19. Random number generators. Available online at
https://kb.palisade.com/index.php?pe=kb.paee&id=25 (accessed November 9, 2022).
Palisade. (2018). Palisade Knowledge Base: 2.18. Latin Hypercube versus Monte Carlo sampling.
Available online at https://kb.palisade.com/index.php?pe=kb.paee&id=28 (accessed November
9, 2022).
Palisade. (2022). Define correlation matrix. Available online at
https://help.palisade.eom/v8/en/@RISK/l-Define/5-CoiTelation/Define-Correlation-Matrix.htm
(accessed November 9, 2022).
Parsons Eneineerine Science. (1997). Allied Signal Aerospace Greenwood, South Carolina indoor air
sampling and air quality investigation [TSCA Submission], In Letter from Allied Signal Inc to
USEPA re indoor air sampling and air quality investigations at Illinois and S Carolina facilities,
with attachments and dated 12/15/1997. (OTS0559390. 96-980000052. TSCATS/445531b).
Allied Signal Incorporated.
Patankar. SC; Dodiva. SK; Yadav. GD. (: Cascade engineered synthesis of ethyl benzyl
acetoacetate and methyl isobutyl ketone (MIBK) on novel multifunctional catalyst. J Mol Catal
Chem 409: 171-182. http://dx.doi.ore .molcata.2015.08.018
PetefU Kisso da Silva < \ntun^ Wilhelm i \ .tLmuro. ET: Gtaeser. J: Kaefer D, 1 inden.
R. (2015). Evaluation of genotoxicity in workers exposed to low levels of formaldehyde in a
furniture manufacturing facility. Toxicol Ind Health 32: 1763-1773.
http://dx.doi. ore/10.1177/074S 4250
Phoenix Brands. (2007). Fab/Dynamo/ABC/Ajax 2x heavy duty liquid detergent. Available online at
https://www.whatsinproducts.eom//brands/show msds/1/9592 (accessed January 7, 2020).
Price Health Hazard Evaluation Determination, Report No. HE 77-41-505, General
American Transportation Corporation, Masury, Ohio, July 1978. (HE 77-41-505). Cincinnati,
OH: National Institute for Occupational Safety and Health.
https://www.cdc.eov/niosh/hhe/reports/pdfs/ ;
Price Health Hazard Evaluation Determination, report HE 78-13-577, Equitable Bag
Company, Inc, Florence, Kentucky. (HE 78-13-577). Cincinnati, OH: National Institute for
Occupational Safety and Health, https://www.cdc.eov/niosh/hhe/reports/pdfs/78-13-577.pdf
Quern en . Occupational exposure to atmospheric emissions produced during live gun firing.
Environment and Pollution 2: 57-69. http://dx.doi.ore/10.5539/ep.v2n4p57
Rivei Health Hazard Evaluation Report No. 75-143-333, Unitog Company, Warrensburg,
Missouri. (HHE-75-143-333). Cincinnati, OH: National Institute for Occupational Safety and
Health, https://www.cdc.eov/niosh/hhe/reports/pdfs df
Page 168 of 313
-------
Robinson. CF; Waxweiler. ^ 1 t twlei < > PsS6). Mortality among production workers in pulp and
paper mills. Scand J Work Environ Health 12: 552-560. http://dx.doi. . s iweh J 101
Rodriguez. M; West. C; Brueck. SE. (2012). Air contaminant, noise, and dermal hazards during
aluminum beverage can manufacturing - Texas. (HETA 2008-0099-3152). Rodriguez, M; West,
C; Brueck, SE.
Romanazzi. \ . Pino \ . Uellisnrio \ . Mengozzi « eluso. M; Pazzi. M; Bugiani. M, \ erlato. G;
Bono. R. (2013). 15-F2t isoprostane as biomarker of oxidative stress induced by tobacco smoke
and occupational exposure to formaldehyde in workers of plastic laminates. Sci Total Environ
442: 20-25. http://dx.doi.o /i.scitotenv.2012.10.057
Rope Health Hazard Evaluation Determination Report No. 74-86-269, Owens-Corning
Fiberglass Corporation, Newark, Ohio. (HHE-77-31-432). Cincinnati, OH: National Institute for
Occupational Safety and Health, https://www.cdc.gov/niosh/hhe/reports/pdfs/74-86-269.pdf
Rossiter. WJ. In Mathev. RG. (1985). Urea-formaldehyde foam insulations: a review of their properties
and performance. (NBS Technical Note 1210). Washington, DC: U.S. Department of Commerce.
https://search.proqiiest.com/docview/141957377accoun
Rothman 'x km »} c.mith. MT; Vermeulen. R; Zhang. L. (2017). Response to letter to the editor of
Carcinogenesis by Pira et al., 2017 [Letter], Carcinogenesis 38: 1253-1255.
http://dx.doi.oo 93/carcin/bgxl 11
Rovira. J; Domingo. JL. (2 . Human health risks due to exposure to inorganic and organic chemicals
from textiles: A review [Review], Environ Res 168: 62-69.
http://dx.doi.oo /res.2018.09.027
R }. Histology and pathology laboratories. Chemical hazard prevention and medical/health
surveillance [Review], AAOHN J 47: 199-205. http://dx.doi.oi 7999904700502
80). Environmental assessment of iron casting. (PB80187545).
https://search.proquest.eom/docview/l Ski '>'s's)accounn0 i
Saarv. Ml; House. RA; Holness. PL. (2001). Dermatitis in a particleboard manufacturing facility.
Contact Derm 44: 325-330. http://dx.doi. 14/i. 1600-0536.2001.044006325.x
Salisl Health Hazard Evaluation Report 96-0091-2597 Photoart (Stannard Associates,
Inc.) Fredricksburg, Virginia September 1996. (HETA #96-0091-2597). Cincinnati, OH:
National Institute for Occupational Safety and Health.
Sancini. A; Rosati. MY; De Sio. S: Casale. T; Caciari. T; Samperi. I; Sacco. C; Fortunate. BR;
PimpinelLi r% \ii4reo: t i *.nnei. G, i oinei. F. (2014). Exposure to formaldehyde in health
care: an evaluation of the white blood count differential. G Ital Med Lav Ergon 36: 153-159.
Scarselli rfiati. M; Di Marzio. D; Iavicoli. S. (2017). National Estimates of Exposure to
Formaldehyde in Italian Workplaces. Ann Work Expo Health 61: 33-43.
http://dx.doi.oo 93/ann weh/wxw004
Schever. LE; Kachman. SD; Polsani. M. (2001). Use of soy protein hydrolyzate to reduce formaldehyde
emissions from pigment print pastes. AATCC Rev 1: 45-48.
Schripp. T; Wensing. M. (2009). Emission of VOCs and SVOCs from electronic devices and office
equipment. In E Uhde; T Salthammer (Eds.), Organic indoor air pollutants (2nd ed., pp. 405-
430). Weinheim, Germany: Wiley, http://dx.doi.org/10.1002/9783527628889.ch 17
Schwenscn .11', I'riis. I T, Menne. T; Flyvholm. MA; Johansen JIV (2017). Contact allergy to
preservatives in patients with occupational contact dermatitis and exposure analysis of
preservatives in registered chemical products for occupational use. Int Arch Occup Environ
Health 90: 319-333. http://dx.doi.org, 10 100 ^ 0041:0 01 I A)3-5
Scotts. (2024). Scotts Turf Builder Lawn Food [Website], https://scotts.com/en-us/shop/fert.ilizers/scotts-
turf-buil der-lawn -food/ scotts-turf-builder-n orth em -1 awn -food. htm 1
Seow. WJ; Zham 1 \ oimeul'n L \ .mg. X; Hu. W; Bassi^ r% \ h Shiels. MS; Kemp. TJ; Shen.
M; Qiu. C; Reiss. B; Beane Freeman. LE; Blair. A; Kim. C; Guo. W; Wen 1 It 1 Pttnc 1
Page 169 of 313
-------
Huang. H; Smith. MT; Hildesheim \ ^ othman N, 1 an . (2015). Circulating
immune/inflammation markers in Chinese workers occupationally exposed to formaldehyde.
Carcinogenesis 36: 852-857. http://dx.doi.ore/10.1093/carcin/bev055
Shinohara. N: Okazaki. Y; Mizukoshi akamatsu. S. (2019). Exposure to benzene, toluene,
ethylbenzene, xylene, formaldehyde, and acetaldehyde in and around gas stations in Japan.
Chemosphere 222: 923-931. http://dx.doi.ore/10 J016/i.chemosphere..0 rs 01 I
SI A. (2020). SI A comments on the draft scope of the risk evaluation for formaldehyde. Available online
at https://www.reeiilations.eov/comment/EPA-HQ-OPPT-2018-0438-0053
Solenis. (2020). Comment submitted by D wight Chapman, Strategic Marketing Manager, Sol en is LLC
regarding the draft scope of the risk evaluation for formaldehyde. Available online at
https://www.reeiilations.eov/comment/EPA-HQ-OPPT-2018-0438-0038
Sousa. FW; C aval can te. KM; Rocki (' \. Nascimenm M i ^nreir. \ (2015). Carbonyl compounds
from urban activities and their associated cancer risks: The influence of seasonality on air quality
(Fortaleza-Ce, Brazil). Urban Climate 13: 110-121.
http://dx.doi.ore/10.1016/i.uclim.l01 0 '< 00 I
Stantec ChemRisk. (2023). Submission by ACC Formaldehyde TSCA. Risk Evaluation Consortium
regarding analysis of industrial hygiene monitoring data for formaldehyde manufacturing and
processing. Washington, DC: American Chemistry Council.
https://www.reeiilations.eov/comment/EPA-HQ-OPPT-20
Steinsvae. K; Bratveit. M; Moen. BE. (2007). Exposure to carcinogens for defined job categories in
Norway's offshore petroleum industry, 1970 to 2005. Occup Environ Med 64: 250-258.
http://dx.doi.on >em.2006.028225
Stern mont. II; Halperin. WE; Murthy. LI; Hills. BW; Faien. JM. (1987). Mortality of chrome
leather tannery workers and chemical exposures in tanneries. Scand J Work Environ Health 13:
108-117. http://dx.dou weh.2073
Susst Health hazard evaluation report No. HETA-91 -0239-2509, Medite Of New Mexico,
Las Vegas, New Mexico (pp. 91-0239). (HETA 91-0239-2509). Cincinnati, OH: National
Institute of Occupation Safety and Health.
Taylor. AW. (2004). Fertilizers. Hoboken, NJ: John Wiley & Sons.
http://dx.doi.on 10 100:0 I i. 3961.0605182008150606.a0 i pub2
Teixeiu J\ , Miranda. S; Monteiro R 1 opes. FY; Madureim j, Si(va. GV; Pestana. N; Pinto. E;
Vilar. VI; Boaventura. RA. (2013). Assessment of indoor airborne contamination in a
wastewater treatment plant. Environ Monit Assess 185: 59-72. http://dx.doi.ore/ 0661-
TFI. (2024). Comment submitted by The Fertilizer Institute (TFI): Formaldehyde (Docket Number EPA-
HQ-OPPT-2023-0613) [Public Comment], https://www.reeulations.eov/comment/EPA-HQ-
QPPT-2023-06134
I iociation. (2024). Comment submitted by The Toy Association: Formaldehyde (Docket
Number EPA-HQ-OPPT-2023-0613) [Public Comment],
https://www.reeiilations.eov/comment/EPA-HQ-OPPT-2023-0613-0218
Thetkathuek neratanasuk. T; Ekburanawat. W. (2016). Respiratory Symptoms due to
Occupational Exposure to Formaldehyde and MDF Dust in a MDF Furniture Factory in Eastern
Thailand. 2016: 3705824. http://dx.doi.ore/10.1155/2016/3705824
Thon stad. M; Ellinesen. DG; Molander. P. (2005). Air formaldehyde and solvent
concentrations during surface coating with acid-curing lacquers and paints in the woodworking
and furniture industry. J Environ Monit 7: 586-591. http://dx.doi.ore/10.1039 87i
Tian. S; Ecoff. S; Sebroski. J; Miller. J; Rickenbacker. H; Bilec. M. (2018). An indoor air quality
evaluation in a residential retrofit project using spray polyurethane foam. J Occup Environ Hyg
15: 363-375. http://dx.doi.ore/lO 10N0/1545962-i JOIN I SJN.'O:
Page 170 of 313
-------
Tikuisis. T; Phibbs. MR; Sonnenb-n ^ K«. ( r s°5). Quantitation of employee exposure to emission
products generated by commercial-scale processing of polyethylene. Am Ind Hyg Assoc J 56:
809-814. http://dx.doi.tnv 10 IQSQ/1542M I
Tikui lor. G; Sonnenberg. K; Cavanagh. J. (2010). Quantification of Emission Compounds
Generated During Commercial-Scale Processing of Advanced Sclairtech TM Polyethylene.
Journal of Plastic Film and Sheeting 26: 167-191. http://dx.doi.on 10 I I s •'6087910380 '< 10
Tomer. A; Kane The great port mismatch. U.S. goods trade and international transportation.
The Global Cities Initiative. A joint project of Brookings and JPMorgan Chase.
https://www.brookines.edii/wp-content/iiploads/2015/06/brekssrvygcifreiehtnetworks.pdf
Tuonn i I ngstrom r% 'x i em el a. R; Svinhufvud. J; Reiiula. K. (2000). Emission of ozone and organic
volatiles from a selection of laser printers and photocopiers. Appl Occup Environ Hyg 15: 629-
634. http://dx.doi.org/10.1080/10473220050Q75635
TVA. (1991). Formaldehyde in urea product and urea production — Status report with cover letter dated
02/01/91 and attachments [TSCA Submission], (OTS0000803; FYI-OTS-0391-0803;
TSCATS/416031). Unocal Corp.
. Employee Tenure News Release. Available online at
http://www.bls.eov/news.release/archives/tenure 0918! m
May 2016 Occupational Employment and Wage Estimates: National Industry-
Specific Estimates. Available online at http://www.bls.eov/oes/tables.htm
3). U.S. Census Bureau of Labor Statistics Data from 2021. Washington, DC: United
States Department of Labor. Retrieved from https://www.bls.eov/oes/tables.htm
LIS Census Bureau > s ) Statistics of U.S. Businesses (SUSB).
https://www.census.gov/data/tables/2015/econ/susb/2Q15-susb-annual.html
1J.S Census Bureau. (2019a). Survey of Income and Program Participation data. Available online at
https://www.censiis.gov/programs-siirveys/sipp/data/datasets/2008-panel/wff il (accessed
May 16, 2019).
isus Bureau. (2019b). Survey of Income and Program Participation: S1PP introduction and
history. Washington, DC. https://www.census.gov/programs-survevs/sipp/about/sipp-
introducti on -history .html
Chemical engineering branch manual for the preparation of engineering
assessments. Volume I. Ceb Engineering Manual. Washington, DC: Office of Pollution
Prevention and Toxics, US Environmental Protection Agency.
https://nepis.epa. gov/Exe/ZyPIJRL.cgi?Dockey=P 10000VS.txt
Locating and estimating air emissions from sources of formaldehyde (revised).
(450491012). U.S. EPA. https://www3.epa.gov/ttn/chief/le/formal.pdf
2a). Guidelines for exposure assessment. Federal Register 57( 104):22888-22938 [EPA
Report], In Risk Assessment Forum. (EPA/600/Z-92/001). Washington, DC.
http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm7dei
2b). A laboratory method to determine the retention of liquids on the surface of hands
[EPA Report], (EPA/747/R-92/003). Washington, DC.
. Generic Scenario: Application of Agricultural Pesticides.
4a). Guidelines for Statistical Analysis of Occupational Exposure Data: Final. United
States Environmental Protection Agency :: U.S. EPA.
4b). National Emission Standards for Hazardous Air Pollutants from the Synthetic
Organic Chemical Manufacturing Industry for Process Vents, Storage Vessels, Transfer
Operations, and Wastewater. (40 C.F.R. §§ 63.110 and 63.126-130). Washington, DC.
4c). Water treatment disinfectants application - generic scenario for estimating
occupational exposures and environmental releases. Washington, DC. https://www.epa.gov/tsca-
screening-tools/using-predictive-methods-assess-exposure-and-fate-under-tsca
Page 171 of 313
-------
5a). Ap-42: Chapter 4.12 - Manufacture of rubber products [EPA Report], Washington,
DC. https://www.epa.gov/air-emissions-factors-and-quantification/ap-42-fifth-edition-volume-i-
chapter-4-evaporation-loss-0
5b). AP-42: Chapter 8 - Inorganic chemical industry [EPA Report], Washington, DC.
https://www.epa.eov/air-emissions-factors-and-qiiantification/ap-42-fifth-edition-voliime-i-
ch apter- 8 -in or gani c-ch em i cal -0
5c). Protocol for Equipment Leak Emission Estimates. (EPA-453/R-95-017). Research
Triangle Park, NC: Office of Air and Radiation, Office of Air Quality and Planning Standards.
https://www3.epa.gov/ttn/chief/efdocs/equiplks.pdf
Flexographic printing - generic scenario for estimating occupational exposures and
environmental releases: Draft. Washington, DC. https://www.epa.gov/tsca-screening-tools/using-
predictive-methods-assess-exposure-and-fate-under-tsca
2001). Leather tanning - Generic scenario for estimating occupational exposures and
environmental releases (draft). Washington, DC. https://www.epa.gov/tsca-screening-
tools/using-predictive-methods-assess-exposure-and-fate-under-tsca
2002). Flexographic ink options: A cleaner technologies substitutes assessment. Volume 1
[EPA Report], (EPA 744-R-02-001A). Cincinnati, OH: U.S. Environmental Protection Agency,
National Service Center for environmental Publications.
https://www.epa.gov/sites/defaiilt/files/2014-01/dociiments/flexographic ctsa votl.pdf
2003). Estimating 2003 building-related construction and demolition materials amounts.
https://www.epa.gov/smm/estimating-2QQ3-building-related-construction-and-demolition-
materials-amounts
2004a). Additives in plastics processing (converting into finished products) -generic scenario
for estimating occupational exposures and environmental releases. Draft. Washington, DC.
2004b). Spray coatings in the furniture industry - generic scenario for estimating
occupational exposures and environmental releases.
I v
-------
2020c). Final scope of the risk evaluation for formaldehyde; CASRN 50-00-0. (EPA 740-R-
20-014). Washington, DC: Office of Chemical Safety and Pollution Prevention.
https://www.epa.eov/sites/defaiilt/files/2020-09/documents/casm 50-00-0-
formaldehyde finalscope cor.pdf
2021a). Application of spray polyurethane foam insulation - Generic scenario for estimating
occupational exposures and environmental releases - Final. Washington, DC.
https://www.epa.eov/tsca-screenine-tools/iisine-predictive-methods-assess-exposiire-and-fate-
under-tsca
2021b). Draft systematic review protocol supporting TSCA risk evaluations for chemical
substances, Version 1.0: A generic TSCA systematic review protocol with chemical-specific
methodologies. (EPA Document #EPA-D-20-031). Washington, DC: Office of Chemical Safety
and Pollution Prevention. https://www.reeulations.eov/document/< " \ ^ IQ-OPPT-2Q. I Ojl i.-
0005
2021c). Generic model for central tendency and high-end inhalation exposure to total and
respirable Particulates Not Otherwise Regulated (PNOR). Washington, DC: Office of Pollution
Prevention and Toxics, Chemical Engineering Branch.
202Id). Use of chemicals in fuels and related products - Generic scenario for estimating
occupational exposures and environmental releases (Methodology review draft). Washington,
DC: Office of Pollution Prevention and Toxics, Risk Assessment Division.
2022a). Chemical repackaging - Generic scenario for estimating occupational exposures and
environmental releases (revised draft) [EPA Report], Washington, DC.
2022b). Commercial use of automotive detailing products - Generic scenario for estimating
occupational exposures and environmental releases (Methodology review draft) [EPA Report],
Washington, DC: U.S. Environmental Protection Agency, Office of Pollution Prevention and
Toxics, Risk Assessment Division.
2022c). Discharge Monitoring Report (DMR) data for 1,4-dioxane, 2013-2019. Washington,
DC. Retrieved from https://echo.epa.eov/trends/loadine-tool/water-pollution-search
2022d). Emission scenario document on chemicals used in hydraulic fracturing (draft). Paris,
France: Organization for Economic Co-operation and Development.
2022e). National emissions inventory (NE1). Available online at https://www.epa.gov/air-
emissions-inventories/national-emissions-inventorv (accessed August 31, 2022).
202211. Toxics Release Inventory (TRI) data for 1,4-dioxane, 2013-2019. Washington, DC.
Retrieved from https://www.epa.eov/toxics-release-inventorv-tri-proeram/tri-data-and4ools
2023a). AP-42: Chapter 4 - Evaporation loss sources. Washington, DC.
3b). AP-42: Chapter 5 - Petroleum industry. Washington, DC.
2023c). Draft Risk Evaluation for Formaldehyde - Systematic Review Supplemental File:
Data Quality Evaluation and Data Extraction Information for Environmental Release and
Occupational Exposure. Washington, DC: Office of Pollution Prevention and Toxics, Office of
Chemical Safety and Pollution Prevention.
2023d). Use of laboratory chemicals - Generic scenario for estimating occupational
exposures and environmental releases (Revised draft generic scenario) [EPA Report],
Washington, DC: U.S. Environmental Protection Agency, Office of Pollution Prevention and
Toxics, Existing Chemicals Risk Assessment Division.
2024a). Human Health Risk Assessment for Formaldehyde. Washington, DC: U.S.
Environmental Protection Agency, Office of Pollution Prevention and Toxics.
2024b). Risk Evaluation for Formaldehyde - Systematic Review Supplemental File: Data
Quality Evaluation and Data Extraction Information for Environmental Release and
Occupational Exposure. Washington, DC: Office of Pollution Prevention and Toxics, Office of
Page 173 of 313
-------
Chemical Safety and Pollution Prevention. https://www.reeulations.eov/docket/EPA-HQ-OPPT-
2018-0438
USD A. (2015). 2014 Agricultural Chemical Use Survey - Corn Highlights [Website],
https://www.nass.iisda.eov/Siirveys/Giiide to NASS Surveys/Chemical Use/2( >m Highl
ights/
USTMA. (2019). U.S. Tire Manufacturers Association: Tire manufacturing and tire materials overview
slides. Presentation presented at Meeting with US Tire Manufacturers Association and EPA to
discuss conditions of use for formaldehyde, Washington, DC.
USTMA. (2020). Comment submitted by U.S. Tire Manufacturers Association (USTMA), dated
06/08/2020. (EPA-HQ-OPPT-2018-0438-0054). Washington, DC.
https://www.reeiilations.eov/comment/EPA-HQ-OPPT-2018-0438-0054
USTMA. (2024). Comment submitted by U.S. Tire Manufacturers Association (USTMA):
Formaldehyde (Docket Number EPA-HQ-OPPT-2023-0613) [Public Comment],
https://www.reeiilations.eov/comment/EPA-HQ-OPPT-2023-0613-0266
Vaaiasaari. K; Kulovaara. M; Joutti. A; Schuttz. E; Soli am o. K. (2004). Hazardous properties of paint
residues from the furniture industry. J Hazard Mater 106: 71-79.
http://dx.doi.oo jhazmat.2003.11.004
Van der 982). Formaldehyde measurements in Dutch houses, schools and offices in the years
1977-1980. Atmos Environ 16: 2471-2478. http://dx.doi.oi '0004-6981(82)90137-8
van der Willieen. AH; Stolz. E; van Joost. T. (1987). Sensitization to phenol formaldehyde resin in
rubber glue. Contact Derm 16: 291-292. http://dx.doio: -0536.1987.tb01467.x
VaneronsveM « < terckmair c. \ -nbinnen. K \ on Leeuw. C; Bormans. C. (2010). Isocvanate and
total inhalable particulate air measurements in the European wood panel industry. Int J Hyg
Environ Health 213: 475-488. http://dx.doi.oi ^ 10 101 )/uiheh.2010.0N 01 I
Vicenu' i T» kibeii 1 Custodio. D; Alves. CA. (2017). Assessment of the indoor air quality in copy
centres at Aveiro, Portugal. Air Qual Atmos Health 10: 117-127.
http://dx.doi.on 10 100 ^ i is
Vieeas. S: Ladeira. C; Gomes. M; Nunes 1 r% t do. AI. Pdhta. J. (2013). Exposure and genotoxicity
assessment methodologies - the case of formaldehyde occupational exposure. Current Analytical
Chemistry 9: 476-484. http://dx.doi.ore/10.2174 BOO 17
Vieeas. S: Prist; . Aspects to consider for selection of chemical risk assessment methodology:
The case of formaldehyde occupational exposure. WIT Trans Ecol Environ 132: 23-32.
http://dx.doi.ore/10.2495/ETQX100031
Viegas, S; Prista, J; Gomes, M. (2009). WIT Transactions on Biomedicine and Health
Exposure assessment: the influence of environmental monitoring methodology: unknown.
http://dx.doi.ore/10.2495/EHR090341
Vinzents. P; Laurse A national cross-sectional study of the working environment in the
Danish wood and furniture industry: Air pollution and noise. Ann Occup Hyg 37: 25-34.
http://dx.doi.oo 93/annhye/37.1.25
Wan. H; Wane. XM; B ten. J. (2014). Recycling wood composite panels: Characterizing
recycled materials. BioResources 9: 7554-7565.
Wasson. S: Novak. L; Enele. L. (2024). The average yard size by state [Website],
https://todayshomeowner.com/lawn-earden/euides/averaee-yard-size/
Westbere. H; Lofstedt. H; S el den. \ 1 tlj . ,s .ystrom. P. (2005). Exposure to low molecular weight
isocyanates and formaldehyde in foundries using Hot Box core binders. Ann Occup Hyg 49:
719-725. http://dx.doij 3/annhve/mei040
Wicks. ZW. Jr; Jones. FN. (2013). Coatings. In Kirk-Othmer encyclopedia of chemical technology.
Hoboken, NJ: John Wiley & Sons.
http://dx.doi.on 10 1002/0 i I : '.8961.0315012023090311 .aOl ,pub3
Page 174 of 313
-------
Williams. LL. (2002). Amino resins and plastics. In Kirk-Othmer encyclopedia of chemical technology.
New York, NY: John Wiley & Sons.
http://dx.doi.on 10 1002/0 I I : '.jv\ I 01 I '»0914230'M : I .\a01.pub2
Xu. W; Stev 316). A comparison of engineering controls for formaldehyde exposure during
grossing activities in health care anatomic pathology laboratories. J Occup Environ Hyg 13: 529-
537. http://dx.doi.org/10.108Q/15459i I
Zendehdel. R; Abdolmaleki. P; Jouni. FJ; Mazinani. M. (2017). Genetic variation and risk of DNA
damage in peripheral blood lymphocytes of Iranian formaldehyde-exposed workers. Hum Exp
Toxicol 37: 960327117728385. http://dx.doi.ore 10 I I 0960 II :8385
Zhang. L; Tang. X; Rothman. x \ ^iroeulen. R; Ji. Z: Shen. M; Qiu. C; Guo. W: Liu. S: Reiss. B;
t V'^man 1 r% N ilubbard. AE; Hua. M; Bktu \ \tlvran. N: Ruan. X; Alter. BP; Xin. KX;
Li. S; Moore. LE; Kim. S; Xie ^ . Haves. RB; Azuma. M; Hauptmann. M; Xiong, J; Stewart, P;
Li, L; Rappaport, SM; Huang, H; Fraumeni, JF, Jr; Smith, MT; Lan, Q. (2010). Occupational
exposure to formaldehyde, hematotoxicity, and leukemia-specific chromosome changes in
cultured myeloid progenitor cells. Cancer Epidemiol Biomarkers Prev 19: 80-88.
http://dx.doi.on -0762
Zimn HETA 92-287-2294 March 1993 Federal Records Center, Dayton,
Ohio. (HETA 92-287-2294). National Institute for Occupational Safety and Health.
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APPENDICES
Appendix A KEY ABBREVIATIONS AND ACRONYMS
AC
Acute concentrations
ACA
American Coatings Association
ACC
American Chemistry Council
ACGM
American Conference of Governmental Industrial Hygienists
ADC
Average daily concentration
ADD
Average daily dose
ADR
Acute Dose Rate
APDR
Acute potential dermal dose rates
APF
Assigned protection factor
BLS
Bureau of Labor Statistics
CASRN
Chemical Abstracts Service Registry Number
CDR
Chemical Data Reporting
CEB
Chemical Engineering Branch
CEHD
Chemical Exposure Health Data
CFR
Code of Federal Regulations
COU
Condition of use
CT
Central tendency
CWA
Clean Water Act
DIY
Do-it-yourself
DMR
Discharge monitoring report
EPA
Environmental Protection Agency
ESD
Emission Scenario Document
FIFRA
Federal Insecticide, Fungicide, and Rodenticide Act
FT
Full-text (screening)
GS
Generic Scenario
HAP
Hazardous air pollutant
HE
High-end
HERO
Health and Environmental Research Online (EPA Database)
HHE
Health hazard evaluation (NIOSH)
IBC
Intermediate bulk container
IFC
Industrial Function Category
IIOAC
Integrated Indoor/Outdoor Air Calculator (EPA)
Koc
Soil organic carbon: water partitioning coefficient
Kow
Octanol: water partition coefficient
LADC
Lifetime Average Daily Concentration
LOD
Limit of detection
Log Koc
Logarithmic organic carbon: water partition coefficient
Log Kow
Logarithmic octanol: water partition coefficient
LOQ
Limit of quantitation
MDF
Medium-density fiberboard
MRD
Methodology Review Draft (EPA)
MW
Molecular weight
NAICS
North American Industry Classification System
ND
Non-detect
NEI
National Emissions Inventory
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NIOSH
National Institute for Occupational Safety and Health
NPDES
National Pollutant Discharge Elimination System
OARS
Occupational Alliance for Risk Science
OAQPS
Office of Air Quality Planning and Standards
OCF
One-component foam
OCSPP
Office of Chemical Safety and Pollution Prevention
OD
Operating days
OECD
Organisation for Economic Co-operation and Development
OES
Occupational exposure scenario
ONU
Occupational non-user
OPPT
Office of Pollution Prevention and Toxics
OSHA
Occupational Safety and Health Administration
PBZ
Personal breathing zone
PECO
Population, exposure, comparator, and outcome
PEL
Permissible exposure limit (OSHA)
PESS
Potentially exposed or susceptible subpopulations
PF
Protection factor
PNOR
Particulates not otherwise regulated
POD
Point of departure
POTW
Publicly owned treatment works (wastewater)
PPE
Personal protective equipmen
ppm
Parts per million
PV
Production volume
QA/QC
Quality assurance/quality control
REL
Recommended exposure limit (NIOSH)
RCRA
Resource Conservation and Recovery Act
SACC
Science Advisory Committee on Chemicals (EPA)
SAR
Supplied-air respirator
SCBA
Self-contained breathing apparatus
SDS
Safety data sheet
SDWA
Safe Drinking Water Act
SHEDS-HT
Stochastic Human Exposure and Dose Simulation-High Throughput
SIC
Standard Industrial Classification
SOC
Standard Occupational Classification
SPF
Spray polyurethane foam
STEL
Short-term exposure limit (OSHA)
SUSB
Statistics of United States Businesses
TIAB
Title/abstract (screening)
TLV
Threshold limit value (ACGIH)
TRI
Toxics Release Inventory
TSCA
Toxic Substances Control Act
TWA
Time-weighted average
U.S.
United States
VOC
Volatile organic compound
VP
Vapor pressure
wt%
Weight percent
Page 177 of 313
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Appendix B LIST OF SUPPLEMENTAL FILES
(1) Risk Evaluation for Formaldehyde CASRN: 50-00-0, Supplemental File - Use of Automotive
Care, Lubricants, and Water Treatment Products
(2) Risk Evaluation for Formaldehyde CASRN: 50-00-0, Supplemental File - Use of Fertilizer OES
(3) Risk Evaluation for Formaldehyde CASRN: 50-00-0, Supplemental File - Use in Oilfield Well
Production
(4) Risk Evaluation for Formaldehyde CASRN: 50-00-0, Supplemental File - Model Results for
Occupational Exposure Modeling
Provides a summary of the calculated exposure results for the modeled OESs. The summary table
includes the high-end and central tendency exposure results presented in units of both ppm and mg/m3.
Additionally, the file summarizes the model input parameters and equations used to calculate the
exposures by exposure point for each scenario. Model results contain the inputs and outputs from the
Monte Carlo modeling.
(5) Risk Evaluation for Formaldehyde CASRN: 50-00-0, Supplemental Information on Occupational
Inhalation Monitoring Data Summary - Provides a compilation of monitoring data from
systematic review and OSHA CEHD data used in the occupational exposure assessment. The
monitoring data is sorted into tabs for each of the OESs and includes information such as the
HERO ID of the source, the data quality rating of the source, details of the monitoring data
results, and worker/ONU distinctions. This file is not comprehensive of all available
formaldehyde monitoring data, which is provided in (U.S. EPA. 2023c). Selected sources were
pulled from ( )23c) during evidence integration based on evidence integration
considerations (temporal representativeness, attributable to the exposure scenario, etc.).
(6) Draft Risk Evaluation for Formaldehyde (HCHO) - Systematic Review Supplemental File: Data
Quality Evaluation and Data Extraction Information for Environmental Release and
Occupational Exposure (U. 2023c) - Provides a compilation of tables for the data
extraction and data quality evaluation information for Formaldehyde (HCHO). Each table shows
the data point, set, or information element that was extracted and evaluated from a data source
that has information relevant for the evaluation of environmental release and occupational
exposure. This supplemental file may also be referred to as the "HCHO Data Quality Evaluation
and Data Extraction Information for Environmental Release and Occupational Exposure."
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Appendix C MODEL APPROACHES AND PARAMETER
SELECTION
This appendix presents the modeling approach and model equations used in estimating occupational
exposures for each of the applicable OESs. The models were developed through review of the literature
and consideration of existing EPA/OPPT models, ESDs, and/or GSs. An individual model input
parameter could either have a discrete value or a distribution of values. EPA assigned statistical
distributions based on reasonably available literature data. A Monte Carlo simulation (a type of
stochastic simulation) was conducted to capture variability in the model input parameters. The
simulation was conducted using the Latin hypercube sampling method in @Risk Industrial Edition,
Version 8.0.0. The Latin hypercube sampling method generates a sample of possible values from a
multi-dimensional distribution and is considered a stratified method, meaning the generated samples are
representative of the probability density function (variability) defined in the model. EPA performed the
model at 100,000 iterations to capture a broad range of possible input values, including values with low
probability of occurrence.
EPA used the 95th and 50th percentile Monte Carlo simulation model result values for assessment. The
95th percentile value represents the high-end exposure level, whereas the 50th percentile value
represents the typical exposure level. The following subsections detail the model design equations and
parameters for each of the OESs.
This appendix section discusses the standard models used by EPA to estimate environmental releases of
chemicals and occupational inhalation exposures. All the models presented in this section are models
that were previously developed by EPA and are not the result of any new model development work for
this risk evaluation. Therefore, this appendix does not provide the details of the derivation of the model
equations which have been provided in other documents such as the ChemSTEER User Guide for the
EPA/OPPT Mass Balance Inhalation Model ( 3), Chemical Engineering Branch Manual
for the Preparation of Engineering Assessments, Volume 1 ( ). Evaporation of pure
liquids from open surfaces (Arnold and Engel. 2001). and Evaluation of the Mass Balance Model Used
by the References Environmental Protection Agency for Estimating Inhalation Exposure to New
Chemical Substances (Fehrenbacher and Hummel. 1996). The models include loss fraction models as
well as models for estimating chemical vapor generation rates used in subsequent model equations to
estimate the volatile releases to air and occupational inhalation exposure concentrations.
The EPA/OPPT Penetration Model estimates releases to air from evaporation of a chemical from an
open, exposed liquid surface. This model is appropriate for determining volatile releases from activities
that are performed indoors or when air velocities are expected to be less than or equal to 100 feet per
minute. The EPA/OPPT Penetration Model calculates the average vapor generation rate of the chemical
from the exposed liquid surface using EquationApx C-l:
EquationApx C-l.
C.l EPA/OPPT Standard Models
(8.24 X 10"8) * (MW0 B3S) * F
T0 05 * [D ¦ * \/~P
1 y ^opening V1
Where:
MW
Vapor generation rate for activity [g/s]
Formaldehyde molecular weight [g/mol]
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VP = Formalin vapor pressure [torr]
Rateair speed = Air speed [cm/s]
Dopening = Diameter of opening [cm]
T = Temperature [K]
P = Pressure [torr]
The EPA/OPPT Mass Transfer Coefficient Model estimates releases to air from the evaporation of a
chemical from an open, exposed liquid surface. This model is appropriate for determining this type of
volatile release from activities that are performed outdoors or when air velocities are expected to be
greater than 100 feet per minute. The EPA/OPPT Mass Transfer Coefficient Model calculates the
average vapor generation rate of the chemical from the exposed liquid surface using EquationApx C-2:
EquationApx C-2.
(1.93 x lO"7) * (MW °78) * FcorrectionJactor * VP * Rate°a™speed * (0.25nD,
opening J
U- 1
29 1 MW
}activity
Where:
u activity
MW
VP
Rate,
D
T
air_speed
opening
To.4Do.n sjf _ 5 87^/3
1 ^opening vv 1 >->•*->/ j
Vapor generation rate for activity [g/s]
Formaldehyde molecular weight [g/mol]
Formalin vapor pressure [torr]
Air speed [cm/s]
Diameter of opening [cm]
Temperature [K]
The EPA's Office of Air Quality Planning and Standards (OAQPS) AP-42 Loading Model estimates
releases to air from the displacement of air containing chemical vapor as a container/vessel is filled with
a liquid. This model assumes that the rate of evaporation is negligible compared to the vapor loss from
the displacement and is used as the default for estimating volatile air releases during both loading
activities and unloading activities. This model is used for unloading activities because it is assumed
while one vessel is being unloaded another is assumed to be loaded. The EPA/OAQPS AP-42 Loading
Model calculates the average vapor generation rate from loading or unloading using Equation Apx C-3:
Equation Apx C-3.
G
CTtl
Fsaturation_factor*MW *Vcontainer*^^85A *Fcorrection_fact0r*VP*-
RATE
fill
activity
Where:
u activity
Fsaturationj actor
MW
^container
VP
RATE fill
R
T
hr
R*T
Vapor generation rate for activity [g/s]
Saturation factor [unitless]
Formaldehyde molecular weight [g/mol]
Volume of container [gal/container]
Formalin vapor pressure [torr]
Fill rate of container [containers/hr]
Universal gas constant [L*torr/mol-K]
Temperature [K]
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For each of the vapor generation rate models, the vapor pressure correction factor (Fcorrectionj actor)
can be estimated using Raoult's Law and the mole fraction of formaldehyde in the liquid of interest.
However, EPA did not utilize a vapor pressure correction factor {i.e., set it as 1) when modeling vapor
generation rates for formaldehyde. This was because the vapor pressure of formalin was used instead of
neat formaldehyde, as neat formaldehyde's vapor pressure exceeds the threshold (35 torr) for the above
models. To account for lower vapor generation rates modeled using formalin's vapor pressure as
compared to neat formaldehyde, EPA did not apply a vapor correction factor.
If calculating an environmental release, the vapor generation rate calculated from one of the above
models (EquationApx C-l. , EquationApx C-2, and EquationApx C-3) is then used along with an
operating time to calculate the release amount:
The EPA/OPPT Mass Balance Inhalation Model estimates a worker inhalation exposure to an estimated
concentration of chemical vapors within the worker's breathing zone using a one box model. The model
estimates the amount of chemical inhaled by a worker during an activity in which the chemical has
volatilized and the airborne concentration of the chemical vapor is estimated as a function of the source
vapor generation rate or the saturation level of the chemical in air. First, the applicable vapor generation
rate model (Equation Apx C-l, Equation Apx C-2, and Equation Apx C-3) is used to calculate the
vapor generation rate for the given activity. With this vapor generation rate, the EPA/OPPT Mass
Balance Inhalation Model calculates the volumetric concentration of formaldehyde using Equation Apx
C-4:
Equation Apx C-4.
Cvactivity = Minimum-.
Where:
Cvactivity
Gactivity
MW
Q
k
T
VP
P
170,000 * 7 * G,
activity
MW * Q * k
1,000,000ppm * VP
Exposure activity volumetric concentration [ppm]
Exposure activity vapor generation rate [g/s]
Formaldehyde molecular weight [g/mol]
Ventilation rate [ftVmin]
Mixing factor [unitless]
Temperature [K]
Formalin vapor pressure [torr]
Pressure [torr]
Mass concentration can be estimated by multiplying the volumetric concentration by the molecular
weight of formaldehyde and dividing by molar volume at standard temperature and pressure. The mass
concentrations for each exposure activity of a given OES can be summed to calculate the 8-hour TWA
for a given worker using Equation Apx C-5:
Equation Apx C-5.
£f=0 Cmi ht
TWA8hr = 8 hours
Where:
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TWA8hr
Crrii
hi
Time-weighted average (8-hour) [mg/m3]
Exposure activity mass concentration [mg/m3]
Exposure activity exposure hours [hrs]
EPA uses the above equations in the formaldehyde occupational exposure models, and EPA references
the model equations by model name and/or equation number within Appendix B.
C.2 Developing Models that Use Monte Carlo Methods
This appendix provides background information on Monte Carlo methods, including an overview of
deterministic and stochastic processes, an overview of the implementation of Monte Carlo methods, and
a discussion of EPA's approach for building models that utilized Monte Carlo methods.
This appendix is only intended to provide general background information; information related to the
specific models for which EPA implemented Monte Carlo methods is included in Appendices C.3
through C.9.
C.2.1 Background on Monte Carlo Methods
A deterministic process has a single output (or set of outputs) for a given input (or set of inputs). The
process does not involve randomness and the direction of the process is known.
In contrast, stochastic processes are non-deterministic. The output is based on random trials and can
proceed via multiple, or even infinite, directions.
Monte Carlo methods fall under the umbrella of stochastic modeling. Monte Carlo methods are a
replication technique for propagating uncertainty through a model. The model is run multiple times, and
each run uses different input values and generates different output values: each run is independent of
each other. The sample of output values is used to estimate the properties of the actual probability
distribution of the outputs.
C.2.2 Implementation of Monte Carlo Methods
The implementation of Monte Carlo methods generally follows the following steps:
1. Define probability distributions for input parameters.
2. Generate a set of input values by randomly drawing a sample from each probability distribution.
3. Execute the deterministic model calculations.
4. Save the output results.
5. Repeat steps 2 through 4 through the desired number of iterations.
6. Aggregate the saved output results and calculate statistics.
Figure Apx C-l illustrates a flowchart of a Monte Carlo method implemented in a Microsoft Excel -
based model using a Monte Carlo add-in tool, such as the Palisade @Risk software.
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Results are Stored until
Desired Iterations are
Met
Iterations
Met
Results Summary
and Descriptive
Statistics
Define
Inputs
Monte Carlo
Add-In Tool
Randomly
Selected
Inputs
Deterministic Model
Outputs
FigureApx C-l. Flowchart of a Monte Carlo Method Implemented in a Microsoft Exeel-Based
Model Using a Monte Carlo Add-In Tool
C.2.3 Building the Model
The steps for building a release or exposure model that incorporates Monte Carlo methods are as
follows:
1. Build the deterministic model.
2. Define probability distributions for input parameters.
3. Select model outputs for aggregation of simulation results.
4. Select simulation settings and run model.
5. Aggregate the simulation results and calculate output statistics.
Each of these steps is discussed in the subsections below.
C.2.3.1 Build the Deterministic Model
First, the model is built as a deterministic model. EPA uses Microsoft Excel in order to use Palisade's
@Risk software that is used for probabilistic analyses in Excel. The model parameters and equations are
programmed into the spreadsheet. Model parameters are programmed in a summary table format for
transparency and to aid in the assignment of probability di stributions. Such summary tables are included
in the model-specific write-ups in Appendices C 3 through C.9.
C.2.3.2 Define Probability Distributions for Input Parameters
Defining a probability distribution for an input parameter generally involves three steps:
1. Select the model input parameters for which probability distributions will be developed.
2. Determine a probability distribution from the available data.
3. Investigate if any parameters are statistically correlated. Define a statistical correlation among
parameters if a correlation is desired.
Step 1: Select Input Parameters for Probability Distribution Development
When selecting parameters for which probability distributions will be developed, the following factors
are considered:
• The availability of data to inform a distribution.
• The dependency of the input parameters on one another.
The sensitivity of the model results to each input parameter.
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Availability of Data to Inform a Distribution: Data sources to investigate for available data to inform
probability distributions of model inputs include but are not limited to the following:
• EPA Generic Scenarios,
• OECD Emission Scenario Documents,
• Peer reviewed literature,
• Published chemical assessments, and
• Other gray literature.1
Model parameters may vary greatly in their available data. There may be a single study that provides
detailed measurements or observation data. There may be multiple studies that provide limited
measurements or observations. There may be only overall statistics available for a parameter. For a
given model development, the available data goes through a systematic review process to evaluate the
data quality, integrate the data, and decide how to use the data.
Dependency of Input Parameters on One Another: The model parameters are evaluated for any
dependency on each other. When each varied parameter is sampled according to its defined probability
distribution, they are sampled independently of each other. Therefore, the value of a sampled parameter
should be independent of the other sampled parameters. An exception is if a statistical correlation is
desired among two or more parameters. Correlating sampled parameters is discussed below in Step 3.
An example of dependency is the relationship between a facility's number of operating days, annual
production volume (PV), and daily PV. These three parameters are not all independent of each other.
The annual PV may be calculated from the daily PV and the operating days. Alternatively, the daily PV
may be calculated from the annual PV and the operating days. Additionally, operating days may be
calculated from the annual PV and daily PV. It is necessary to first understand the mathematical
relationship among these parameters before selecting parameters for which probability distributions will
be developed.
Sensitivity of the Model Results to Each Input Parameter: One consideration in selecting model
parameters for probability distribution development is the sensitivity of the model outputs to each
parameter. A sensitivity analysis can inform how sensitive each model output is to each model input
parameter. EPA may choose to prioritize probability distribution development for parameters to which
model outputs are more sensitive. Since the model outputs are more sensitive to these parameters, it
would be more important to capture variability and/or uncertainty for these parameters compared to
parameters to which model outputs are less sensitive.
A sensitivity analysis is conducted by varying each desired parameter and performing a Monte Carlo
simulation. The varied range for each parameter should be consistent with the expected range in values
for the parameter. The @Risk software can perform sensitivity analyses. The statistic of the outputs for
which sensitivity is measured, such as mean, mode, or a percentile, can be selected. As the simulation is
run, the software tracks how each output changes with respect to each varied input.
1 Gray literature is defined as the broad category of data/information sources not found in standard, peer-reviewed literature
databases. Gray literature includes data/information sources such as white papers, conference proceedings, technical reports,
reference books, dissertations, information on various stakeholder websites, and various databases.
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Step 2: Determine a Probability Distribution
To determine a probability distribution, first, all the information known about the parameter is evaluated
(Oracle. 2017). The following considerations can help guide summarizing important information about
the parameter (Analvtica. ^ ):
• Discrete or continuous
o Consider whether the parameter is discrete or continuous. Does the parameter have a
finite or countable number of possible values? Is the parameter logical or Boolean such as
having possible values of "yes or no" or "true or false"? Can the parameter be
represented by all real numbers within a domain?
• Bounds
o Consider whether the parameter has bounds. A parameter may have a lower bound and/or
an upper bound. Alternatively, a parameter may be unbounded and can range to negative
and/or positive infinity.
• Modes
o Consider whether the parameter has one or more modes. Does the parameter have no
mode (such as represented by a uniform distribution)? If it has a mode, is it unimodal or
multimodal? If multimodal, is the parameter a combination of two or more populations?
In which case, the parameter may be best separated into its separate components and then
develop probability distributions for the individual components.
• Symmetric or skewed
o Consider whether the parameter is symmetric or skewed. If skewed, consider whether the
parameter is positively skewed (thicker upper tail) or negatively skewed (thicker lower
tail).
Second, review standard probability distributions and identify possible candidates that meet the
considerations identified in the first step (Oracle. 2017). The following are common probability
distributions:
• Uniform distribution
o A uniform distribution has finite upper and lower bounds and all values between the
bounds have equal probability.
• Triangular distribution
o A triangular distribution has finite upper and lower bounds and a modal value. The modal
value is the value that occurs most frequently. If the most frequent value is not known
another statistic, such as the mean or a percentile, could be used to define the triangular
distribution.
• Normal distribution
o The parameters of a normal distribution are its mean and standard deviation. A normal
distribution is unbounded, and values range from negative to positive infinity. If desired,
the range of values of a normal distribution may be truncated to finite bounds to prevent
unrealistic values from being sampled.
• Lognormal distribution
o If a variable is lognormally distributed, it means that the logarithm of that variable is
normally distributed. The parameters of a lognormal distribution are its mean and
standard deviation. A lognormal distribution is bounded from zero to positive infinity. A
lognormal distribution may be shifted and its upper bound truncated to fit the observed
data and prevent unrealistic values from being sampled.
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Lastly, select the best suited probability distribution (Oracle. 2017). Review the available data for the
parameter to determine how to define the distribution's parameters. For example, if the only available
data are an overall range (with a minimum and a maximum), then a uniform distribution is the
appropriate distribution to use. If the only available data are an overall range and a mode, then a
triangular distribution is the appropriate distribution to use. If historical data for the parameter are
available, consider data fitting to determine the appropriate distribution and regress the distribution
parameter values.
Step 3: Check for and Define Statistical Correlations
When developing a Monte Carlo model and setting statistical distributions for parameters, EPA
evaluates possible correlations among parameters. When distributions are defined for the parameters,
each parameter is independently sampled on each iteration of the model. This may result in
combinations of parameter values that are not logical for the scenario. In the example of a model that
uses annual PV, daily PV, and operating days as parameters, there are set distributions for annual PV
and operating days, with the daily production volume calculated from the other two parameters. But
annual PV and operating days may be correlated. For example, if a site has a fixed manufacturing
capacity (as determined by the equipment size and production lines), then annual PV is a function of the
number of operating days. A facility is more likely to scale-up or scale-down their annual PV by varying
the operating days rather than varying their daily PV. Varying annual PV and operating days
independently in the model may arrive at value combinations that are not logical. For example, one
iteration may sample a high annual PV value with a low number of operating days that may result in a
high daily production rate that is not logical. In this example, a different probability distribution strategy
may be appropriate, such as defining probability distributions for daily PV and operating days since
those two parameters are likely more independent of each other than annual PV and operating days.
When developing distributions from observed data, there are statistical tests that can be performed to
indicate a statistical correlation. Two common ones are: (1) the Pearson product-moment correlation
coefficient, which measures the linear correlation between two data sets; and (2) Spearman's rank
correlation coefficient, which is a measure of rank correlation and how well a relationship between two
data sets can be described using a monotonic function. A monotonic relationship is one where the two
variables change together but not necessarily at a constant rate (Minitab. 2022). A linear correlation is
necessarily monotonic. But a monotonic correlation is not necessarily linear.
Both the Pearson and Spearman coefficients range from -1 to +1. A value close to ±1 indicates a strong
correlation (either positive or negative). A positive correlation means as one variable increases, the other
also increases. A negative correlation means as one variable increases, the other decreases. A value close
to 0 means a weak or no correlation exists between the variables. The Pearson correlation only measures
linear relationships, and the Spearman correlation only measures monotonic relationships. If two
variables are correlated by a relationship that is neither linear nor monotonic, then the Pearson and
Spearman coefficients would not be informative of the nature of the correlation (Minitab. 2022).
After testing for statistical correlations, statistical correlations can be defined for input parameters using
@Risk. @Risk only uses Spearman coefficients to define statistical correlations among input
parameters. Spearman coefficients to correlate two or more input parameters are defined through a
correlation matrix. The correlation matrix allows the Spearman coefficient to be defined for each pair of
correlated input parameters (Palisade. 2022).
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C.2.3.3 Select Model Outputs for Aggregation of Simulation Results
The last step before running the model is to select the model outputs for which statistical results are
desired. Defining these outputs in @Risk will allow the software to save the output results from each
iteration and aggregate the simulation results over all iterations together.
C.2.3.4 Select Simulation Settings and Run Model
Simulation settings must be defined before running the model. Important simulation settings include the
number of iterations, the sampling method, and the random number generator.
• Number of iterations: Generally speaking, a larger number of iterations is desired to ensure
adequate sampling and representation of lower probability events. The number of iterations to
achieve a desired margin of error for a given confidence interval for an output can be calculated
using the Central Limit Theorem (OJ>n I'1 JO I \ <\tlisade. 2015a). The equation shows that the
margin of error is inversely proportional to the square root of the number of iterations. Therefore,
the greater the number of iterations, the smaller the margin of error. Calculating the number of
iterations can be difficult as the sample standard deviation is not known beforehand. EPA
typically uses 100,000 iterations to ensure convergence and have minimal cost to the simulation
time.
• Sampling method: The sampling method is the method used to draw random samples from the
input parameter probability distributions. @Risk uses two methods: Latin Hypercube (the
default) and Monte Carlo. Monte Carlo sampling is a purely random sampling method. This can
lead to clustering and under-representing low probability events. Latin Hypercube sampling is a
stratified sampling method. This ensures the sampled input parameter distribution matches the
assigned probability distribution closely. EPA typically uses Latin Hypercube sampling because
it is efficient and can achieve convergence with fewer iterations than Monte Carlo sampling
(Palisade. 2018).
• Random number generator: The random number generator is used to generate pseudorandom
numbers that are used in an algorithm to draw random samples from the probability distributions.
The @Risk default is Mersenne Twister, which is a robust and efficient random number
generator (Palisade. 2015b).
C.2.3.5 Aggregate the Simulation Results and Produce Output Statistics
During the simulation, @Risk will save the defined model outputs for aggregation on each iteration.
After the simulation is completed, EPA can generate desired statistical results and distributions of the
defined outputs. EPA typically uses the 50th percentile and 95th percentile of the output as the central
tendency and high-end estimates, respectively.
C.3 Use of Formulations Containing Formaldehyde in Automotive Care
Products Model Approach and Parameters
This appendix presents the modeling approach and equations used to estimate occupational exposures
for formaldehyde during the use of automotive care products OES. This approach utilizes the GS on
Commercial Use of Automotive Detailing Products combined with Monte Carlo simulation (a type of
stochastic simulation).
Based on the GS, EPA identified the following inhalation exposure points:
• Exposure point A: Transfer operation exposures from unloading transport containers; and
• Exposure point B: Application and use of automotive detailing products.
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Occupational exposures for formaldehyde during the use of automotive care products are a function of
formaldehyde's physical properties, container size, mass fractions, and other model parameters. While
physical properties are fixed, some model parameters are expected to vary. EPA used a Monte Carlo
simulation to capture variability in the following model input parameters: ventilation rate, mixing factor,
saturation factor, loss factor, container sizes, working years, operating and exposure days, formaldehyde
concentration in the auto detailing product, annual number of cars detailed per site, use rate of
automotive detailing product per car, and mass concentration of formaldehyde in air for exposure point
B. EPA used the outputs from a Monte Carlo simulation with 100,000 iterations and the Latin
Hypercube sampling method in @Risk to calculate release amounts and exposure concentrations for this
OES.
C.3.1 Model Equations
TableApx C-l provides the models and associated variables used to calculate occupational exposures
for each exposure point within each iteration of the Monte Carlo simulation. EPA used these
occupational exposures to develop a distribution of exposure outputs for the Automotive care OES. The
Agency assumed that the same worker performed each exposure activity resulting in a total exposure
duration of up to 8 hours per day. The variables used to calculate each of the following exposure
concentrations and durations include deterministic or variable input parameters, known constants,
physical properties, conversion factors, and other parameters. The values for these variables are
provided in the following sections. The Monte Carlo simulation calculated an 8-hour TWA exposure
concentration for each iteration using the exposure concentration and duration associated with each
activity and assuming exposures outside the exposure activities were zero. EPA then selected 50th
percentile and 95th percentile values to estimate the central tendency and high-end exposure
concentrations, respectively.
Table Apx C-l. Models and Variables Applied for Exposure Points in the Automotive Care OES
Exposure Point
Model(s) Applied
Variables Used
Exposure point A: Inhalation
exposure during container
unloading or transferring
EPA/OPPT Mass Balance Inhalation
Model with vapor generation rate
from EPA/OAQPS AP-42 Loading
Model
Vapor Generation Rate: Ffa: VP:
Fsaturation_unloading? MW, Vsmall_cont¦>
R; T; RATEfill_smallcont; Q; k; Vm
Exposure Duration: RATEfiii_smaucont
Exposure point B: Container
cleaning exposure
Vapor generation rate assessed both
with the assumption that all
formaldehyde evaporates and with
industry data from the GS
Not applicable
Note that the number of exposure days is set equal to the number of operating days per year multiplied
by a fractional value from the GS. The GS sets a single value at 0.962, which is the EPA standard 250
working days per year divided by a maximum 260 operating days for automotive detailing shops using
data cited in the GS. This value was modified slightly to a uniform distribution from 0.962 to 1 since
automotive detailing shops tend to be smaller businesses where workers may be less likely to take time
off.
C.3.2 Model Input Parameters
Table Apx C-2 summarizes the model parameters and their values for the Automotive care products
OES Monte Carlo simulation. Additional explanations of EPA's selection of the distributions for each
parameter are provided following the table.
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Table Apx C-2. Summary of Parameter Values and Distributions Used in the Automotive Care Products Models
Input Parameter
Symbol
Unit
Deterministic
Values
Uncertainty Analysis Distribution Parameters
Rationale/Basis
Value
Lower
Bound
Upper
Bound
Mode
Distribution
Type
Working Years
WY
years
36
10.4
44
36
Triangular
See Section C.3.10
Indoor or Outdoor
Din Out
1
0
1
1
Discrete
Binary distribution for the
ventilation rate in the indoor
and outdoor scenarios
Ventilation Rate
Q
ft3/min
3,000
500
10,000
3,000
Triangular
See Section C.3.13
237,600
132,000
237,600
-
Uniform
See Section C.3.13
Mixing Factor
k
dimensionles
s
0.5
0.1
1
0.5
Triangular
See Section C.3.14
Saturation Factor Unloading
Fsaturation
unloading
kg/kg
0.5
0.5
1.45
0.5
Triangular
See Section C.3.8
Container Volume
Vsmallcont
gal/container
0.125
0.03125
15
0.125
Triangular
See Section C.3.11
Operating Days
OD
days/yr
260
174
260
260
Discrete
See Section C.3.7
Exposure Days Fraction
Effrac
days/days
0.962
0.962
1
-
Uniform
See Section C.3.5
Formaldehyde Concentration
in the Auto Detailing Product
Ffa
kg/kg
0.1
0.01
0.3
0.1
Triangular
See Section C.3.4
Annual Number of Cars
Detailed per Site
Ncars
cars/yr
2,191
1609
3213
2191
Triangular
See Section C.3.3
Use Rate of Auto Detailing
Products per Car
Vcar
gal/car
0.015625
0.0078125
0.125
0.015625
Discrete
See Section C.3.3
Activity B Mass
Concentration of Chemical
in Air (Application and Use
of Automotive Detailing
Products)
Cms
mg/m3
0.89
0.005
3.7
0.89
Discrete
Discrete distribution from GS
Formaldehyde Molar
Volume
Vm
L/mol
24.45
-
-
-
-
Physical property
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Input Parameter
Symbol
Unit
Deterministic
Values
Uncertainty Analysis Distribution Parameters
Rationale/Basis
Value
Lower
Bound
Upper
Bound
Mode
Distribution
Type
Formaldehyde Molecular
Weight
MW
g/mol
30.026
-
-
-
-
Physical property
Fill Rate of Small Container
RATEfin_
smallcont
containers/
hr
60
-
-
-
-
See Section C.3.12
Lifetime years
LT
years
78
-
-
-
-
See Section C.3.6
Averaging time over a
lifetime (chronic)
ATc
hours
683,280
-
-
-
-
Calculated
Hours exposed per day for
activity B
hs
hours
5
-
-
-
-
From GS
Assessed Vapor Pressure
VP
Torr
1.3
-
-
-
-
Physical property
Formaldehyde Weight
Fraction in formalin
Fformalin
kg/kg
0.37
-
-
-
-
Concentration of
formaldehyde in formalin
Auto Detailing Product
Density
vhOprod
kg/L
1
-
-
-
-
Value provided by GS
Gas Constant
R
L*torr/mol-K
62.36367
-
-
-
-
Physical constant
Temperature
T
K
298
-
-
-
-
Process parameter
Pressure
P
ton-
760
-
-
-
-
Process parameter
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C.3.3 Throughput Parameters
The GS on the Commercial Use of Automotive Detailing Products estimates the annual number of cars
detailed per site using information from freestanding shops, carwash combination sites, and cars for
mobile detailing sites. The EPA modeled the distribution for annual number of cars detailed per site
using the recommended range of 1,609 to 3,213 cars with an underlying triangular distribution and a
mode of 2,191 cars. The values sampled from this distribution are multiplied by the values sampled from
the discrete, equal probability distribution for the use rate of automotive detailing products per car to
calculate a value for annual use rate of automotive detailing products per site.
C.3.4 Concentration of Formaldehyde
Reporters for the Use of Automotive Care Products OES in the 2016 CDR data indicated formaldehyde
concentrations of both less than 1 percent and 1 to 30 percent. Additionally, the GS on the Commercial
Use of Automotive Detailing Products specified a default additive concentration of 10 percent. Thus, the
EPA assessed the concentration of formaldehyde in a range from 1 to 30 percent in a triangular
distribution, with a mode of 10 percent.
C.3.5 Exposure Duration
EPA generally uses an exposure duration of 8 hours per day for averaging full shift exposures.
C.3.6 Lifetime Years
EPA assumes a lifetime of 78 years for all worker demographics.
C.3.7 Operating Days
The GS on Commercial Use of Automotive Detailing Products estimates the number of operating days
from employment data obtained through the BLS's Occupational Employment Statistics. The GS
presents a range of operating days from 174 to 260 days/year; this is based on the assumption of 12- or
8-hour shifts respectively. Assuming either 8-, 10-, or 12-hour shifts results in a discrete distribution of
260, 208, and 174 operating days, respectively, with equal probability for each in the Automotive Care
Products Model.
C.3.8 Saturation Factor
The Chemical Engineering Branch Manual for the Preparation of Engineering Assessments, Volume 1
[CEB Manual] indicates that during splash filling, the saturation concentration was reached or exceeded
by misting with a maximum saturation factor of 1.45 ( ). The CEB Manual indicates
that saturation concentration for bottom filling was expected to be about 0.5 ( ). The
underlying distribution of this parameter is not known; therefore, EPA assigned a triangular distribution
based on the lower bound, upper bound, and mode of the parameter. Because a mode was not provided
for this parameter, EPA assigned a mode value of 0.5 for bottom filling as bottom filling minimizes
volatilization ( ). This value also corresponds to the typical value provided in the
ChemSTEER User Guide for the EPA/OAQPS AP-42 Loading Model ( ).
C.3.9 Diameters of Opening
The ChemSTEER User Guide indicates diameters for the openings for various vessels that may hold
liquids in order to calculate vapor generation rates during different activities ( ). In the
simulation developed for the Industrial use of lubricants OES based on the ESD on Chemical Additives
Used in Automotive Lubricants, EPA used the default diameters of vessels from the ChemSTEER User
Guide for container cleaning.
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For container cleaning activities, the ChemSTEER User Guide indicates a single default value of 5.08
cm ( 2015b). Therefore, EPA could not develop a distribution of values for this parameter and
used the single value 5.08 cm.
C.3.10 Worker Years
EPA has developed a triangular distribution for working years. EPA has defined the parameters of the
triangular distribution as follows:
• Minimum value: BLS Current Population Survey (CPS) tenure data with current employer as a
low-end estimate of the number of lifetime working years: 10.4 years;
• Mode value: The 50th percentile tenure data with all employers from Survey of Income and
Program Participation (SIPP) as a mode value for the number of lifetime working years: 36
years; and
• Maximum value: The maximum average tenure data with all employers from SIPP as a high-end
estimate on the number of lifetime working years: 44 years.
This triangular distribution has a 50th percentile value of 31 years and a 95th percentile value of 40
years. EPA uses these values for central tendency and high-end ADC and LADC calculations,
respectively.
The BLS (U ,S. BLS. 2014) provides information on employee tenure with current employer obtained
from the CPS, which is a monthly sample survey of about 60,000 households that provides information
on the labor force status of the civilian non-institutional population aged 16 and over. CPS data are
released every 2 years. The data are available by demographics and by generic industry sectors but are
not available by NAICS codes.
The U.S. Census' (1; S Census Bureau. 2019a) SIPP provides information on lifetime tenure with all
employers. SIPP is a household survey that collects data on income, labor force participation, social
program participation and eligibility, and general demographic characteristics through a continuous
series of national panel surveys of between 14,000 and 52,000 households ( isus Bureau. 2019b).
EPA analyzed the 2008 SIPP Panel Wave 1, a panel that began in 2008 and covers the interview months
of September 2008 through December 2008 ( 'ensus Bureau. 2019a. b). For this panel, lifetime
tenure data are available by Census Industry Codes, which can be crosswalked with NAICS codes.
SIPP data include fields for the industry in which each surveyed, employed individual works
(TJBIND1), worker age (TAGE), and years of work experience with all employers over the surveyed
individual's lifetime.2 Census household surveys use different industry codes than the NAICS codes
used in its firm surveys, so these were converted to NAICS using a published crosswalk (Census
Bureau, 2012b). EPA calculated the average tenure for the following age groups: (1) workers aged 50
and older; (2) workers aged 60 and older; and (3) workers of all ages employed at time of survey. EPA
used tenure data for age group "50 and older" to determine the high-end lifetime working years because
the sample size in this age group is often substantially higher than the sample size for age group "60 and
older." For some industries, the number of workers surveyed, or the sample size, was too small to
provide a reliable representation of the worker tenure in that industry. Therefore, EPA excluded data
where the sample size is less than five from the analysis.
Table Apx C-3 summarizes the average tenure for workers aged 50 and older from SIPP data. Although
2 To calculate the number of years of work experience EPA took the difference between the year first worked
(TMAKMNYR) and the current data year (e.g., 2008). The Agency then subtracted any intervening months when not
working (ETIMEOFF).
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the tenure may differ for any given industry sector, there is no significant variability between the 50th
and 95th percentile values of average tenure across manufacturing and non-manufacturing sectors.
Table Apx C-3. Overview of Average Worker Tenure from U.S. Census SIPP (Age Group 50+)
Industry Sectors
Working Years
Average
50th
Percentile
95th
Percentile
Maximum
Manufacturing sectors (NAICS 31-33)
35.7
36
39
40
Non-manufacturing sectors (NAICS 42-81)
36.1
36
39
44
Source: ("U.S. Census Bureau. 2019aY
Note: Industries where sample size is <5 are excluded from this analysis.
BLS CPS data provides the median years of tenure that wage and salary workers had been with their
current employer. Table Apx C-4 presents CPS data for all demographics (men and women) by age
group from 2008 to 2012. To estimate the low-end value on number of working years, EPA uses the
most recent (2014) CPS data for workers aged 55 to 64 years, which indicates a median tenure of 10.4
years with their current employer. The use of this low-end value represents a scenario where workers are
only exposed to the chemical of interest for a portion of their lifetime working years, as they may
change jobs or move from one industry to another throughout their career.
Table Apx C-4. Median Years of Tenure with Current Emp
oyer by Age Group
Age
January 2008
January 2010
January 2012
January 2014
16 years and over
4.1
4.4
4.6
4.6
16 to 17 years
0.7
0.7
0.7
0.7
18 to 19 years
0.8
1.0
0.8
0.8
20 to 24 years
1.3
1.5
1.3
1.3
25 years and over
5.1
5.2
5.4
5.5
25 to 34 years
2.7
3.1
3.2
3.0
35 to 44 years
4.9
5.1
5.3
5.2
45 to 54 years
7.6
7.8
7.8
7.9
55 to 64 years
9.9
10.0
10.3
10.4
65 years and over
10.2
9.9
10.3
10.3
C.3.11 Container Size
The GS on Commercial Use of Automotive Detailing Products specifies a range of 4 ounces to 15
gallons, with 16-ounce containers being the most common based on reviewed retailer websites. EPA
developed a triangular distribution using this range and mode.
C.3.12 Container Fill Rates
The ChemSTEER User Guide for the ill'A OI'I'T Mass Balance Inhalation Model (U.S. EPA. 2015 b)
provides a typical fill rate of 20 containers per hour for containers with 20 to 100 gallons of liquid and a
typical fill rate of 60 containers per hour for containers with less than 20 gallons of liquid. EPA
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estimates unload rates for containers as equivalent to the fill rates. Therefore, EPA could not develop a
distribution of values for these parameters and used the single value 60 containers/hr.
C.3.13 Ventilation Rate
The CEB Manual ( ) indicates general ventilation rates in industry range from 500 to
10,000 ftVmin, with a typical value of 3,000 ftVmin. The underlying distribution of this parameter is not
known; therefore, EPA assigned a triangular distribution based on an estimated lower bound, upper
bound, and mode of the parameter. The Agency assumed the lower and upper bound using the industry
range of 500 to 10,000 ftVmin and the mode using the 3,000 ftVmin typical value (x v << \ s s .).
Additionally, the CEB Manual indicates a general ventilation rate range from 132,000 to 237,600 ftVmin
with a uniform distribution for worker activities taking place in outdoor settings. Because EPA was not
able to identify industry specific data on how often automotive care products are used indoors or
outdoors, the distributions were both used in the assessment with equal probability.
C.3.14 Mixing Factor
The CEB Manual (U.S. EPA. 1991a) indicates mixing factors may range from 0.1 to 1, with' 1
representing ideal mixing. The CEB Manual references the 1988 ACGIH Ventilation Handbook, which
suggests the following factors and descriptions: 0.67 to 1 for best mixing; 0.5 to 0.67 for good mixing;
0.2 to 0.5 for fair mixing; and 0.1 to 0.2 for poor mixing (\ v « « \ l l,.). The underlying distribution
of this parameter is not known; therefore, EPA assigned a triangular distribution based on the defined
lower and upper bound and estimated mode of the parameter. The mode for this distribution was not
provided; therefore, EPA assigned a mode value of 0.5 based on the typical value provided in the
ChemSTEER User Guide for the EPA/OPPTMass Balance Inhalation Model ( b).
C.3.15 Exposure Days Fraction
The GS on the Commercial Use of Automotive Detailing Products specifies the value of 0.962 for the
exposure days fraction {i.e., the fraction of total operating days that the typical worker is working/
exposed). EPA assessed the exposure days fraction on a uniform distribution from 0.962 to 1 since
automotive detailing shops tend to be smaller businesses where workers may be less likely to take time
off.
C.4 Industrial Use of Lubricants
This appendix presents the modeling approach and equations used to estimate occupational exposures
for formaldehyde during the industrial use of lubricants OES. This approach utilizes the ESD on
Chemical Additives Used in Automotive Lubricants combined with Monte Carlo simulation (a type of
stochastic simulation).
Based on the ESD, EPA identified the following inhalation exposure points:
• Exposure point A: Container unloading or transferring; and
• Exposure point B: Container cleaning.
Occupational exposures for formaldehyde during industrial use of lubricants are a function of
formaldehyde's physical properties, container size, mass fractions, and other model parameters. While
physical properties are fixed, some model parameters are expected to vary. EPA used a Monte Carlo
simulation to capture variability in the following model input parameters: ventilation rate, mixing factor,
air speed, working years, operating days, and unloading saturation factor. The Agency used the outputs
from a Monte Carlo simulation with 100,000 iterations and the Latin Hypercube sampling method in
@Risk to calculate release amounts and exposure concentrations for this OES.
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C.4.1 Model Equations
TableApx C-5 provides the models and associated variables used to calculate occupational exposures
for each exposure point within each iteration of the Monte Carlo simulation. EPA used these
occupational exposures to develop a distribution of exposure outputs for the industrial use of lubricants
OES. EPA assumed that the same worker performed each exposure activity resulting in a total exposure
duration of up to 8 hours per day. The variables used to calculate each of the following exposure
concentrations and durations include deterministic or variable input parameters, known constants,
physical properties, conversion factors, and other parameters. The values for these variables are
provided in the next section. The Monte Carlo simulation calculated an 8-hour TWA exposure
concentration for each iteration using the exposure concentration and duration associated with each
activity and assuming exposures outside the exposure activities were zero. EPA then selected 50th
percentile and 95th percentile values to estimate the central tendency and high-end exposure
concentrations, respectively.
Table Apx C-5. Models and Variables Applied for Exposure Points in the Industrial Use of
Lubricants OES
Exposure Point
Model(s) Applied
Variables Used
Exposure point A: Inhalation
exposure during container
unloading or transferring
EPA/OPPT Mass Balance
Inhalation Model with vapor
generation rate from EPA/OAQPS
AP-42 Loading Model
Vapor generation rate: Ffa: VP:
Fsaturation_unloading > MW, Vimport_cont?
R;T; RATEfill_smallcont; Q; k; VmFA
Exposure Duration: RATEfiii_smaucont
Exposure point B: Container
cleaning exposure
EPA/OPPT Penetration Model or
EPA/OPPT Mass Transfer
Coefficient Model, based on air
speed (Appendix C. 1)
Vapor Generation Rate: Ffa: VP:
Fsaturation loading > MWtcep>
Vsmall_cont¦> ^¦ T, R AT Econf-ciean. Q. k.
VmFA
Exposure duration: Vsmau_cont;
RAT Econtciean
Note that the number of exposure days is set equal to the number of operating days per year up to a
maximum of 250 days per year. If the number of operating days is greater than 250 days per year, EPA
assumed that a single worker would not work more than 250 days per year such that the maximum
exposure days per year was still 250.
C.4.2 Model Input Parameters
Table Apx C-6 summarizes the model parameters and their values for the Use of Lubricants Containing
Formaldehyde Monte Carlo simulation. Additional explanations of EPA's selection of the distributions
for each parameter are provided after this table.
Page 195 of 313
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Table Apx C-6. Summary of Parameter Va
ues and Distributions Used in the Use of Lubricants containing Formaldehyde
Input Parameter
Symbol
Unit
Deterministic
Values
Uncertainty Analysis Distribution Parameters
Rationale/Basis
Value
Lower
Bound
Upper
Bound
Mode
Distribution Type
Working Years
WY
years
36
10.4
44
36
Triangular
BLS/CPS and SIPP
Ventilation Rate
Q
ft3/min
3,000
500
10,000
3,000
Triangular
Chem STEER User Guide/CEB Manual
provided values
Mixing Factor
k
dimensionless
0.5
0.1
1
0.5
Triangular
Chem STEER User Guide/CEB Manual
provided values
Saturation Factor
Unloading
Fsaturation unload
ing
kg/kg
0.5
0.5
1.45
0.5
Triangular
Chem STEER User Guide/CEB Manual
provided values
Operating Days
OD
Days/year
253
249
254
253
Triangular/Discrete
Use of Automotive Lubricants ESD
indicates an expected operating days
range of 250-253 days/yr, with 253
days/yr being the default value; added
one to lower bound and subtracted one
from lower bound to create discrete
triangular distribution
Air Speed
ly.'l TEair speed
cm/s
10
1.3
202.2
-
Lognormal
Distribution using EPA's air speed
model for industrial uses; converted to
ft/min for model use
ft/min
19.7
2.56
398
-
Lognormal
Annual Facility
Throughput (kg/yr)
Qlubricant
kg/yr
40,000
-
-
-
-
Automotive Lubricants ESD
Formaldehyde Molar
Volume
VmFA
L/mol
24.45
-
-
-
-
Molar volume at STP
Formaldehyde
Molecular Weight
MW
g/mol
30.026
-
-
-
-
10.5
Fill Rate of Small
Container
AVI TEfiU smallco
nt
containers/ hr
60
-
-
-
-
Automotive Lubricants ESD
Container Cleaning
Rate
ly.'l TEcont clean
containers/hr
20
-
-
-
-
Automotive Lubricants ESD
Unloading Container
Volume
Vsmallcont
gal/container
5
-
-
-
—
Automotive Lubricants ESD
Hours exposed per
day
ED
hrs/day
8
-
-
-
-
Assuming a full 8-hour shift
Lifetime years
LT
years
78
-
-
-
-
Average lifetime years
Page 196 of 313
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Deterministic
Values
Uncertainty Analysis Distribution Parameters
Input Parameter
Symbol
Unit
Rationale/Basis
Value
Lower
Bound
Upper
Bound
Mode
Distribution Type
Averaging time over
A Tc
hours
683,280
-
-
-
-
Converted lifetime years to hours
a lifetime (chronic)
Formaldehyde Use
of Lubricants Mass
Ffa
kg/kg
0.002
-
-
-
-
CNICNAS. 2006)
Fraction
Diameter of Opening
for Container
Dopening
cm
5.08
-
-
-
-
From 1991 CEB Manual
Cleaning
Assessed Vapor
Pressure
VP
Torr
1.3
-
-
-
-
Vapor pressure of formalin at 20 °C
Gas Constant
R
L*torr/mol-K
62.36367
-
-
-
-
Universal gas constant
Temperature
T
K
298
-
-
-
-
Standard temperature
Pressure
P
ton-
760
-
-
-
-
Standard pressure
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C.4.3 Annual Facility Throughput
The ESD on Chemical Additives Used in Automotive Lubricants estimates the annual facility
throughput from facility data obtained through the U.S. Census Bureau, as well as production data from
automotive servicing shops. The EPA was not able to find OES-specific data on throughput for the
Industrial use of lubricants, so the estimate of 40,000 kg/site-year from Automotive lubricants ESD was
used as surrogate data for this model.
C.4.4 Concentration of Formaldehyde
The inhalation exposures for the Industrial Use of Lubricants Model were assessed at a concentration of
0.2 percent based on data from the 2006 formaldehyde report from the NICNAS (NICNAS. 2006).
C.4.5 Exposure Duration
EPA generally uses an exposure duration of 8 hours per day for averaging full-shift exposures.
C.4.6 Lifetime Years
EPA assumes a lifetime of 78 years for all worker demographics.
C.4.7 Operating Days
The ESD on Chemical Additives Used in Automotive Lubricants estimates the number of operating days
from employment data obtained through the U.S. Bureau of Labor Statistics (BLS) Occupational
Employment Statistics. The ESD presents a range of operating days from 250 to 253 days/year. The
Industrial Use of Lubricants model expanded this range to 249 to 254 days/year in order to account for
the bounds in the discrete triangular distribution having a probability value of zero.
C.4.8 Air Speed
Baldwin and Maynard measured indoor air speeds across a variety of occupational settings in the United
Kingdom (Baldwin and Mavni ?8), specifically, 55 work areas were surveyed. EPA analyzed the
air speed data from Baldwin and Maynard and categorized the air speed surveys into settings
representative of industrial facilities and representative of commercial facilities. EPA fit separate
distributions for these industrial and commercial settings and used the industrial distribution for this
OES.
EPA fit a lognormal distribution for the data set as consistent with the authors' observations that the air
speed measurements within a surveyed location were lognormally distributed and the population of the
mean air speeds among all surveys were lognormally distributed (Baldwin and Maynard. 1998). Since
lognormal distributions are bound by zero and positive infinity, EPA truncated the distribution at the
largest observed value among all of the survey mean air speeds.
EPA fit the air speed surveys representative of industrial facilities to a lognormal distribution with the
following parameter values: mean of 22.414 cm/s and standard deviation of 19.958 cm/s. In the model,
the lognormal distribution is truncated at a minimum allowed value of 1.3 cm/s and a maximum allowed
value of 202.2 cm/s (largest surveyed mean air speed observed in Baldwin and Maynard) to prevent the
model from sampling values that approach infinity or are otherwise unrealistically small or large
(Baldwin and Mayr >98).
Baldwin and Maynard only presented the mean air speed of each survey. The authors did not present the
individual measurements within each survey. Therefore, these distributions represent a distribution of
Page 198 of 313
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mean air speeds and not a distribution of spatially variable air speeds within a single workplace setting.
However, a mean air speed (averaged over a work area) is the required input for the model.
C.4.9 Saturation Factor
The Chemical Engineering Branch Manual for the Preparation of Engineering Assessments, Volume 1
[CEB Manual] indicates that during splash filling, the saturation concentration was reached or exceeded
by misting with a maximum saturation factor of 1.45 ( ). The CEB Manual indicates
that saturation concentration for bottom filling was expected to be about 0.5 ( ). The
underlying distribution of this parameter is not known; therefore, EPA assigned a triangular distribution
based on the lower bound, upper bound, and mode of the parameter. Because a mode was not provided
for this parameter, EPA assigned a mode value of 0.5 for bottom filling as bottom filling minimizes
volatilization ( ). This value also corresponds to the typical value provided in the
ChemSTEER User Guide for the EPA/OAQPS AP-42 Loading Model ( ).
C.4.10 Diameters of Opening
The ChemSTEER User Guide indicates diameters for the openings for various vessels that may hold
liquids in order to calculate vapor generation rates during different activities ( ). In the
simulation developed for the Industrial Use of Lubricants OES based on the ESD on Chemical Additives
Used in Automotive Lubricants, EPA used the default diameters of vessels from the ChemSTEER User
Guide for container cleaning.
For container cleaning activities, the ChemSTEER User Guide indicates a single default value of 5.08
cm ( 2015b). Therefore, EPA could not develop a distribution of values for this parameter and
used the single value 5.08 cm from the ChemSTEER User Guide.
C.4.11 Worker Years
EPA has developed a triangular distribution for working years. EPA has defined the parameters of the
triangular distribution as follows:
• Minimum value: BLS CPS tenure data with current employer as a low-end estimate of the
number of lifetime working years: 10.4 years;
• Mode value: The 50th percentile tenure data with all employers from SIPP as a mode value for
the number of lifetime working years: 36 years; and
• Maximum value: The maximum average tenure data with all employers from SIPP as a high-end
estimate on the number of lifetime working years: 44 years.
This triangular distribution has a 50th percentile value of 31 years and a 95th percentile value of 40
years. EPA uses these values for central tendency and high-end ADC and LADC calculations,
respectively.
The BLS (U ,S. BLS. 2014) provides information on employee tenure with current employer obtained
from the CPS, which is a monthly sample survey of about 60,000 households that provides information
on the labor force status of the civilian non-institutional population age 16 and over. CPS data are
released every 2 years. The data are available by demographics and by generic industry sectors but are
not available by NAICS codes.
The U.S. Census" ( ;nsus Bureau. 2019a) SIPP provides information on lifetime tenure with all
employers. SIPP is a household survey that collects data on income, labor force participation, social
program participation and eligibility, and general demographic characteristics through a continuous
series of national panel surveys of between 14,000 and 52,000 households (\] S Census Bureau. 2019b).
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EPA analyzed the 2008 SIPP Panel Wave 1, a panel that began in 2008 and covers the interview months
of September 2008 through December 2008 ( 'ensus Bureau. 2019a. b). For this panel, lifetime
tenure data are available by Census Industry Codes, which can be crosswalked with NAICS codes.
SIPP data include fields for the industry in which each surveyed, employed individual works
(TJBIND1), worker age (TAGE), and years of work experience with all employers over the surveyed
individual's lifetime.3 Census household surveys use different industry codes than the NAICS codes
used in its firm surveys, so these were converted to NAICS using a published crosswalk (Census
Bureau, 2012b). EPA calculated the average tenure for the following age groups: (1) workers aged 50
and older, (2) workers aged 60 and older, and (3) workers of all ages employed at time of survey. EPA
used tenure data for age group "50 and older" to determine the high-end lifetime working years, because
the sample size in this age group is often substantially higher than the sample size for age group "60 and
older." For some industries, the number of workers surveyed, or the sample size, was too small to
provide a reliable representation of the worker tenure in that industry. Therefore, EPA excluded data
where the sample size is less than five from our analysis.
TableApx C-7 summarizes the average tenure for workers aged 50 and older from SIPP data. Although
the tenure may differ for any given industry sector, there is no significant variability between the 50th
and 95th percentile values of average tenure across manufacturing and non-manufacturing sectors.
Table Apx C-7. Overview of Average Worker Tenure from U.S. Census SIPP (Age Group 50+)
Industry Sectors
Working Years
Average
50th
Percentile
95th
Percentile
Maximum
Manufacturing sectors (NAICS 31-33)
35.7
36
39
40
Non-manufacturing sectors (NAICS 42-81)
36.1
36
39
44
Source: ("U.S. Census Bureau. 2019a).
Note: Industries where sample size <5 are excluded from this analysis.
BLS CPS data provides the median years of tenure that wage and salary workers had been with their
current employer. Table Apx C-8 presents CPS data for all demographics (men and women) by age
group from 2008 to 2012. To estimate the low-end value on number of working years, EPA uses the
most recent (2014) CPS data for workers aged 55 to 64 years, which indicates a median tenure of 10.4
years with their current employer. The use of this low-end value represents a scenario where workers are
only exposed to the chemical of interest for a portion of their lifetime working years, as they may
change jobs or move from one industry to another throughout their career.
3 To calculate the number of years of work experience EPA took the difference between the year first worked
(TMAKMNYR) and the current data year {i.e., 2008). EPA then subtracted any intervening months when not working
(ETIMEOFF).
Page 200 of 313
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Table Apx C-8. Median Years of Tenure with Current Employer by Age Group
Age
January 2008
January 2010
January 2012
January 2014
16 years and over
4.1
4.4
4.6
4.6
16 to 17 years
0.7
0.7
0.7
0.7
18 to 19 years
0.8
1.0
0.8
0.8
20 to 24 years
1.3
1.5
1.3
1.3
25 years and over
5.1
5.2
5.4
5.5
25 to 34 years
2.7
3.1
3.2
3.0
35 to 44 years
4.9
5.1
5.3
5.2
45 to 54 years
7.6
7.8
7.8
7.9
55 to 64 years
9.9
10.0
10.3
10.4
65 years and over
10.2
9.9
10.3
10.3
C.4.12 Container Size
The ESD on Chemical Additives Used in Automotive Lubricants assumed a container volume of 5
gallons per container for each of the assessed worker activities. The 5-gallon container assumption
comes from the ChemSTEER User Guide for the EPA/OPPT Mass Balance Inhalation Model (U.S.
) provided values for small containers, which are assumed to be the type of containers used
in unloading of lubricants and container cleaning activities.
C.4.13 Container Fill Rates
The ChemSTEER User Guide for the EPA/OPPT Mass Balance Inhalation Model (U.S. EPA. 2015 b)
provides a typical fill rate of 20 containers per hour for containers with 20 to 100 gallons of liquid and a
typical fill rate of 60 containers per hour for containers with less than 20 gallons of liquid. EPA
estimates unload rates for containers as equivalent to the fill rates. Therefore, EPA could not develop a
distribution of values for these parameters and used the single value 20 containers/hr or 60 containers/hr
from the ChemSTEER User Guide depending upon the exposure activity.
C.4.14 Ventilation Rate
The CEB Manual ( ) indicates general ventilation rates in industry range from 500 to
10,000 ftVmin, with a typical value of 3,000 ftVmin. The underlying distribution of this parameter is not
known; therefore, EPA assigned a triangular distribution based on an estimated lower bound, upper
bound, and mode of the parameter. EPA assumed the lower and upper bound using the industry range of
500 to 10,000 ftVmin and the mode using the 3,000 ftVmin typical value ( ).
C.4.15 Mixing Factor
The CEB Manual (U.S. EPA. 1991a) indicates mixing factors may range from 0.1 to 1, with' 1
representing ideal mixing. The CEB Manual references the 1988 ACGIH Ventilation Handbook, which
suggests the following factors and descriptions: 0.67 to 1 for best mixing; 0.5 to 0.67 for good mixing;
0.2 to 0.5 for fair mixing; and 0.1 to 0.2 for poor mixing (\ v « « \ l l,.). The underlying distribution
of this parameter is not known; therefore, EPA assigned a triangular distribution based on the defined
lower and upper bound and estimated mode of the parameter. The mode for this distribution was not
provided; therefore, EPA assigned a mode value of 0.5 based on the typical value provided in the
ChemSTEER User Guide for the EPA/OPPT Mass Balance Inhalation Model ( b).
Page 201 of 313
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C.5 Use of Formulations Containing Formaldehyde for Water Treatment
Model Approach and Parameters
For Use of Formulations containing Formaldehyde for Water treatment OES, the Tank Truck and
Railcar Loading and Unloading Release and Inhalation Exposure Model is used to estimate the airborne
concentration associated with generic chemical loading scenarios at industrial facilities. This model is
discussed in Appendix C.7.
C.6 Use of Fertilizers Containing Formaldehyde in Outdoors including
Lawns
C.6.1 Model Equations
This appendix presents the modeling approach and equations used to estimate occupational exposures
for formaldehyde during the Use of Fertilizer containing Formaldehyde in Outdoors Including Lawns
OES. This approach utilizes the GS on Application of Agricultural Pesticide combined with Monte
Carlo simulation (a type of stochastic simulation).
Based on the GS, EPA identified the following inhalation exposure points:
• Exposure point A: Container unloading or transferring; and
• Exposure point B: Equipment cleaning; and
• Exposure point C: Generic Model for Central Tendency and High-End Inhalation Exposure to
Total and Respirable PNOR.
Occupational exposures for formaldehyde during use of fertilizer containing formaldehyde for in
outdoors including lawns are a function of formaldehyde's physical properties, container size, mass
fractions, and other model parameters. While physical properties are fixed, some model parameters are
expected to vary. EPA used a Monte Carlo simulation to capture variability in the following model input
parameters: ventilation rate, mixing factor, saturation factor, working years, formaldehyde mass fraction
in the urea-formaldehyde product, hours exposed for exposure point B, and production volume. EPA
used the outputs from a Monte Carlo simulation with 100,000 iterations and the Latin Hypercube
sampling method in @Risk to calculate release amounts and exposure concentrations for this OES.
C.6.2 Model Input Parameters
Table Apx C-9 provides the models and associated variables used to calculate occupational exposures
for each exposure point within each iteration of the Monte Carlo simulation. EPA used these
occupational exposures to develop a distribution of exposure outputs for the Use of fertilizer OES. EPA
assumed that the same worker performed each exposure activity resulting in a total exposure duration of
up to 8 hours per day. The variables used to calculate each of the following exposure concentrations and
durations include deterministic or variable input parameters, known constants, physical properties,
conversion factors, and other parameters. The values for these variables are provided in the next section.
The Monte Carlo simulation calculated an 8-hour TWA exposure concentration for each iteration using
the exposure concentration and duration associated with each activity and assuming exposures outside
the exposure activities were zero. EPA then selected 50th percentile and 95th percentile values to
estimate the central tendency and high-end exposure concentrations, respectively.
Page 202 of 313
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Table Apx C-9. Models and Variables Applied for Exposure Points in the Use of Fertilizer PES
Exposure Point
Model(s) Applied
Variables Used
Exposure point A:
Inhalation exposure
during container
unloading
EPA/OPPT Mass Transfer
Coefficient Model, based on air
speed (Appendix A. 1)
Vapor Generation Rate: Ffa: VP:
Fsaturationjunloading? MW, Vimp0rf- C0nf-, R. T.
RATEfiii_smaiicont, Q, k, Vtufa
Exposure Duration: RATEfill_smallcont
Exposure point B:
Equipment cleaning
exposure
EPA/OPPT Mass Transfer
Coefficient Model, based on air
speed (Appendix A.l)
Vapor Generation Rate: Ffa: VP:
FsaturationJoading? MW , Vsmall_cont¦> ^^¦
RATEcont ciean, Q. k. Vi7i\ \
Exposure Duration. Vsmaii_cont? RATEcon^ ciean
Table Apx C-10 summarizes the model parameters and their values for the Use of Fertilizers containing
Formaldehyde Monte Carlo simulation. Additional explanations of EPA's selection of the distributions
for each parameter are provided after this table.
Page 203 of 313
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Table Apx C-10. Summary of Parameter Va
ues and Distri
jutions Used in the Use of Fertilizer Models
Deterministic
Values
Uncertainty Analysis Distribution Parameters
Input Parameter
Symbol
Unit
Rationale/Basis
Value
Lower
Bound
Upper
Bound
Mode
Distribution
Tvpe
Working Years
WY
years
36
10.4
44
36
Triangular
See Section C.6.10
Ventilation Rate
Q
ft3/min
237,000
237,000
3,300,000
237,000
Triangular
See Section C.6.13
Mixing Factor
k
dimensionless
0.5
0.1
1
0.5
Triangular
See Section C.6.14
Saturation Factor
Fsaturation unloa
kg/kg
0.5
0.5
1.45
0.5
Triangular
See Section C.6.8
Unloading
ding
Formaldehyde Mass
Fraction in Urea-
FFAJert
kg/kg
0.001
-
-
-
See Section C.6.4
Formaldehyde
Product
Hours Exposed per
Day for Activity B
(Equipment
Cleaning)
hs
hours/site-day
4
0.5
4
4
Triangular
See Section C.6.15
Daily Site Use Rate
Qlandscaping
lbs/day
N/A
Uniform
See Section C.6.3
of Fertilizer -
5,681
462.16
10,900
Landscaping
Days Exposed per
Year - Landscaping
EF landscaping
days/year
175
100
250
-
Discrete
Daily Site Use Rate
of Fertilizer -
Qagricultural
lbs/day
165942
-
-
-
-
See Section C.6.3
Agricultural
Days Exposed per
Year - Agricultural
EFagricultur
al
days/year
16
1
30
-
Discrete
Number of Sites
Ns
sites
2,212
-
-
-
-
See Section G.28
Operating Days
OD
days/site-yr
250
-
-
-
-
Generic OES Estimate
Formaldehyde Molar
Volume
VmFA
L/mol
24.45
-
-
-
-
Physical property
Formaldehyde
Molecular Weight
MW
g/mol
30.026
-
-
-
-
Physical property
Fill Rate of Small
RA TEflll smallc
containers/ hr
60
—
—
—
—
Container
ont
Page 204 of 313
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Input Parameter
Symbol
Unit
Deterministic
Values
Uncertainty Analysis Distribution Parameters
Rationale/Basis
Value
Lower
Bound
Upper
Bound
Mode
Distribution
Type
Container Size
Vcont
gal/ container
25
1040-
-
-
See Section C.6.11
Diameter Opening for
Container Unloading
D container
cm
5.08
-
-
-
-
See Section C.6.9
Hours exposed per
day
ED
hrs/day
8
-
-
-
-
Standard value
Lifetime years
LT
years
78
-
-
-
-
See Section C.6.6
Averaging time over
a lifetime (chronic)
ATc
hours
683280
-
-
-
-
Calculated
Diameter of Opening
for Equipment
Cleaning
D equipment
cm
92
See Section C.6.9
RATEairspeed
AVI TEair speed
ft/min
440
-
-
-
-
See Section C.6.7
Assessed Vapor
Pressure
VP
Torr
1.3
-
-
-
-
Physical property of formalin
Fertilizer Density
vhOfertilizer
kg/L
1
-
-
-
-
See Section C.6.16
Gas Constant
R
L*torr/mol-K
62.36367
-
-
-
-
Physical Constant
Temperature
T
K
298
-
-
-
-
Assumed Process Parameter
Pressure
P
ton-
760
-
-
-
-
Assumed Process Parameter
Page 205 of 313
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C.6.3 Fertilizer Use Rate
Agricultural Scenario
The average farm size in the United States is approximately 439 acres. The amount of nitrogen (N)
applied varies based on soil type, type of crop, and location (USDA. 2016). EPA assumed values for
corn, using the average of 144 lb N per acre are applied for corn (USDA. ). EPA calculated 165,942
lb of fertilizer per site is assumed based on 38-0-0 slow-release fertilizer.
Lawn and Landscape Scenario
The land application area is expected to vary widely between commercial sites and residential sites. EPA
assume that a high-end application area would be a golf course using 100 acres (Aseca. 2024). which
does not account for portions of the land area that will be driving lanes, housing or otherwise not
requiring fertilizer. For residential sites, EPA assumed 0.53 acres or 23,301 sq ft based average yard
sizes across the U.S. (Wasson et at.. 2024). The Agency used a commercial/consumer fertilizer product
to estimate amount of fertilizer applied per sq ft.(Scotts. 2024). EPA calculated 10,900 lb fertilizer used
for commercial landscaping (high-end) and 571bs of fertilizer for average yard per application (low-end).
C.6.4 Concentration of Formaldehyde
The inhalation exposures for the Use of Fertilizers Model was 0.1 percent based on formaldehyde report
data from the Tennessee Valley Authority (TVA. 1991).
C.6.5 Exposure Duration
EPA generally uses an exposure duration of 8 hours per day for averaging full-shift exposures.
C.6.6 Lifetime Years
EPA assumes a lifetime of 78 years for all worker demographics.
C.6.7 Air Speed
Baldwin and Maynard measured indoor air speeds across a variety of occupational settings in the United
Kingdom (Baldwin and Mavn 98), specifically, 55 work areas were surveyed. EPA analyzed the
air speed data from Baldwin and Maynard and categorized the air speed surveys into settings
representative of industrial facilities and representative of commercial facilities. The Agency fit separate
distributions for these industrial and commercial settings and used the industrial distribution for this
OES.
EPA fit a lognormal distribution for the data set as consistent with the authors' observations that the air
speed measurements within a surveyed location were lognormally distributed and the population of the
mean air speeds among all surveys were lognormally distributed (Baldwin and Maynard. 1998). Because
lognormal distributions are bound by zero and positive infinity, EPA truncated the distribution at the
largest observed value among all of the survey mean air speeds.
EPA fit the air speed surveys representative of industrial facilities to a lognormal distribution with the
following parameter values: mean of 22.414 cm/s and standard deviation of 19.958 cm/s. In the model,
the lognormal distribution is truncated at a minimum allowed value of 1.3 cm/s and a maximum allowed
value of 202.2 cm/s (largest surveyed mean air speed observed in Baldwin and Maynard) to prevent the
model from sampling values that approach infinity or are otherwise unrealistically small or large
(Baldwin and Maynard. 1998).
Page 206 of 313
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Baldwin and Maynard only presented the mean air speed of each survey. The authors did not present the
individual measurements within each survey. Therefore, these distributions represent a distribution of
mean air speeds and not a distribution of spatially variable air speeds within a single workplace setting.
However, a mean air speed (averaged over a work area) is the required input for the model.
C.6.8 Saturation Factor
The Chemical Engineering Branch Manual for the Preparation of Engineering Assessments, Volume 1
[CEB Manual] indicates that during splash filling, the saturation concentration was reached or exceeded
by misting with a maximum saturation factor of 1.45 ( ). The CEB Manual indicates
that saturation concentration for bottom filling was expected to be about 0.5 ( ). The
underlying distribution of this parameter is not known; therefore, EPA assigned a triangular distribution
based on the lower bound, upper bound, and mode of the parameter. Because a mode was not provided
for this parameter, EPA assigned a mode value of 0.5 for bottom filling as bottom filling minimizes
volatilization ( ). This value also corresponds to the typical value provided in the
ChemSTEER User Guide for the EPA/OAQPS AP-42 Loading Model ( ).
C.6.9 Diameters of Opening
The ChemSTEER User Guide indicates diameters for the openings for various vessels that may hold
liquids in order to calculate vapor generation rates during different activities ( ). In the
simulation developed for the Use of fertilizer OES, EPA used the default diameters of vessels from the
ChemSTEER User Guide for container cleaning.
For container unloading activities, the ChemSTEER User Guide indicates a single default value of 5.08
cm ( 2015b). Therefore, EPA could not develop a distribution of values for this parameter and
used the single value 5.08 cm from the ChemSTEER User Guide.
For equipment cleaning activities, the ChemSTEER User Guide indicates a single default value of 92 cm
( 2015b). Therefore, EPA could not develop a distribution of values for this parameter and
used the single value 5.08 cm from the ChemSTEER User Guide.
C.6.10 Worker Years
EPA has developed a triangular distribution for working years. EPA has defined the parameters of the
triangular distribution as follows:
• Minimum value: BLS CPS tenure data with current employer as a low-end estimate of the
number of lifetime working years: 10.4 years;
• Mode value: The 50th percentile tenure data with all employers from SIPP as a mode value for
the number of lifetime working years: 36 years; and
• Maximum value: The maximum average tenure data with all employers from SIPP as a high-end
estimate on the number of lifetime working years: 44 years.
This triangular distribution has a 50th percentile value of 31 years and a 95th percentile value of 40
years. EPA uses these values for central tendency and high-end ADC and LADC calculations,
respectively.
The BLS (U ,S. BLS. 2014) provides information on employee tenure with current employer obtained
from the Current Population Survey (CPS). CPS is a monthly sample survey of about 60,000 households
that provides information on the labor force status of the civilian non-institutional population aged 16
and over; CPS data are released every two years. The data are available by demographics and by generic
industry sectors but are not available by NAICS codes.
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The U.S. Census' ( ;nsus Bureau. 2019a) SIPP provides information on lifetime tenure with all
employers. SIPP is a household survey that collects data on income, labor force participation, social
program participation and eligibility, and general demographic characteristics through a continuous
series of national panel surveys of between 14,000 and 52,000 households ( isus Bureau. 2019b).
EPA analyzed the 2008 SIPP Panel Wave 1, a panel that began in 2008 and covers the interview months
of September 2008 through December 2008 ( 'ensus Bureau. 2019a. b). For this panel, lifetime
tenure data are available by Census Industry Codes, which can be crosswalked with NAICS codes.
SIPP data include fields for the industry in which each surveyed, employed individual works
(TJBIND1), worker age (TAGE), and years of work experience with all employers over the surveyed
individual's lifetime.4 Census household surveys use different industry codes than the NAICS codes
used in its firm surveys, so these were converted to NAICS using a published crosswalk (Census
Bureau, 2012b). EPA calculated the average tenure for the following age groups: (1) workers aged 50
and older, (2) workers aged 60 and older, and (3) workers of all ages employed at time of survey. EPA
used tenure data for age group "50 and older" to determine the high-end lifetime working years, because
the sample size in this age group is often substantially higher than the sample size for age group "60 and
older." For some industries, the number of workers surveyed, or the sample size, was too small to
provide a reliable representation of the worker tenure in that industry. Therefore, EPA excluded data
where the sample size is less than five from our analysis.
TableApx C-l 1 summarizes the average tenure for workers aged 50 years and older from SIPP data.
Although the tenure may differ for any given industry sector, there is no significant variability between
the 50th and 95th percentile values of average tenure across manufacturing and non-manufacturing
sectors.
Table Apx C-ll. Overview of Average Worker Tenure from U.S. Census SIPP (Age Group 50+)
Industry Sectors
Working Years
Average
50th
Percentile
95th
Percentile
Maximum
Manufacturing sectors (NAICS 31-33)
35.7
36
39
40
Non-manufacturing sectors (NAICS 42-81)
36.1
36
39
44
Source: (U.S. Census Bureau, 2019a).
Note: Industries where sample size is <5 are excluded from this analysis.
BLS CPS data provides the median years of tenure that wage and salary workers had been with their
current employer. Table Apx C-12 presents CPS data for all demographics (men and women) by age
group from 2008 to 2012. To estimate the low-end value on number of working years, EPA uses the
most recent (2014) CPS data for workers aged 55 to 64 years, which indicates a median tenure of 10.4
years with their current employer. The use of this low-end value represents a scenario where workers are
only exposed to the chemical of interest for a portion of their lifetime working years, as they may
change jobs or move from one industry to another throughout their career.
4 To calculate the number of years of work experience EPA took the difference between the year first worked
(TMAKMNYR) and the current data year (e.g., 2008). EPA then subtracted any intervening months when not working
(ETIMEOFF).
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Table Apx C-12. Median Years of Tenure with Current Employer by Age Group
Age
January 2008
January 2010
January 2012
January 2014
16 years and over
4.1
4.4
4.6
4.6
16 to 17 years
0.7
0.7
0.7
0.7
18 to 19 years
0.8
1.0
0.8
0.8
20 to 24 years
1.3
1.5
1.3
1.3
25 years and over
5.1
5.2
5.4
5.5
25 to 34 years
2.7
3.1
3.2
3.0
35 to 44 years
4.9
5.1
5.3
5.2
45 to 54 years
7.6
7.8
7.8
7.9
55 to 64 years
9.9
10.0
10.3
10.4
65 years and over
10.2
9.9
10.3
10.3
C.6.11 Container Size
Public comment from the Fertilizer Institute indicates that fertilizer is unloaded from both 275-gallon
totes and 25 to 1,000 kg bags. Converting the 275 gallon tote to kg using the density of fertilizer
parameter of 1 kg/L yields 1,040.985 kg, which was set as the upper bound of the distribution.
C.6.12 Container Fill Rates
The ChemSTEER User Guide provides a typical fill rate of 20 containers per hour for containers with 20
to 100 gallons of liquid and a typical fill rate of 60 containers per hour for containers with less than 20
gallons of liquid. EPA estimates unload rates for containers as equivalent to the fill rates. Therefore, the
Agency could not develop a distribution of values for these parameters and used the single value 20
containers/hr or 60 containers/hr from the ChemSTEER User Guide for the EPA/OPPTMass Balance
Inhalation Model ( 2015b) depending upon the exposure activity.
C.6.13 Ventilation Rate
The CEB Manual ( ) indicates general ventilation rates in industry range from 500 to
10,000 ftVmin, with a typical value of 3,000 ftVmin. The underlying distribution of this parameter is not
known; therefore, EPA assigned a triangular distribution based on an estimated lower bound, upper
bound, and mode of the parameter. EPA assumed the lower and upper bound using the industry range of
500 to 10,000 ftVmin and the mode using the 3,000 ftVmin typical value ( ).
C.6.14 Mixing Factor
The CEB Manual (U.S. EPA. 1991a) indicates mixing factors may range from 0.1 to 1, with' 1
representing ideal mixing. The CEB Manual references the 1988 ACGIH Ventilation Handbook, which
suggests the following factors and descriptions: 0.67 to 1 for best mixing; 0.5 to 0.67 for good mixing;
0.2 to 0.5 for fair mixing; and 0.1 to 0.2 for poor mixing (\ v « « \ l l,.). The underlying distribution
of this parameter is not known; therefore, EPA assigned a triangular distribution based on the defined
lower and upper bound and estimated mode of the parameter. The mode for this distribution was not
provided; therefore, EPA assigned a mode value of 0.5 based on the typical value provided in the
ChemSTEER User Guide for the EPA/OPPT Mass Balance Inhalation Model ( b).
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C.6.15 Hours of Exposure for Equipment Cleaning
The ChemSTEER User Guide provides default values for equipment cleaning activities based on
equipment vessel size. EPA did not identify industry-specific data on the size and nature of the
equipment to be cleaned. The maximum and minimum for this distribution were based on the upper and
lower bounds of possible vessel sizes and quantities for this worker activity.
C.6.16 Fertilizer Density
EPA did not identify any industry-specific data on the density of fertilizers containing formaldehyde.
The density of fertilizer was assessed at 1 kg/L based on the low expected concentrations of additives in
the GS on Application of Agricultural Pesticides.
C.6.17 Generic Model for Central Tendency and High-End Inhalation Exposure to Total
and Respirable PNOR
The Generic Model for Central Tendency and High-End Inhalation Exposure to Total and Respirable
Particulates Not Otherwise Regulated (PNOR) ( ) estimates worker inhalation exposure
to respirable solid particulates using personal breathing zone Particulate, Not Otherwise Regulated
(PNOR) monitoring data from OSHA's CEHD dataset. The CEHD data provides PNOR exposures as 8-
hour TWAs by assuming exposures outside the sampling time are zero, and the data also include facility
NAICS code information for each data point. To estimate particulate exposures for relevant OESs, EPA
used the 50th and 95th percentiles of respirable PNOR values for applicable NAICS codes as the central
tendency and high-end exposure estimates, respectively.
EPA assumed formaldehyde may be carried particulates or mass at the same mass fraction as in the
fertilizer.
Table Apx C-13. Summary of DIDP Exposure Estimates for OESs Using the Generic Model for
Exposure to PNOR
Industry Group
Total PNOR Default - Central
Tendency (50th percentile)
mg/m3
Total PNOR Default
- High-End (PEL)"
mg/m3
Mass Fraction of
Formaldehyde
11 - Agriculture, Forestry,
Fishing and Hunting
2.8
15
0.001
56 - Administrative and Support
and Waste Management and
Remediation Services
2.5
15
0.001
C.7 Use of Formaldehyde for Oilfield Well Production
This appendix presents the modeling approach, and equations used to estimate occupational exposures
for formaldehyde during the use of formaldehyde for Oilfield well production OES. This approach
utilizes the ESD on Chemicals Used in Hydraulic Fracturing ( 2022d) and FracFocus 3.0 data
(GWPC and IOGCC. 2022) combined with Monte Carlo simulation (a type of stochastic simulation).
Based on the ESD ( I2d\ EPA identified the following inhalation exposure points sources
from fracking operations:
• Exposure point A: Transfer operation exposures during container unloading;
• Exposure point B: Exposure to formaldehyde during container cleaning activities; and
• Exposure point C: Exposure to formaldehyde during equipment cleaning activities.
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Occupational exposures for formaldehyde during the use of formaldehyde for oilfield well production
are a function of formaldehyde's physical properties, container size, mass fractions, and other model
parameters. While physical properties are fixed, some model parameters are expected to vary. EPA used
a Monte Carlo simulation to capture variability in the following model input parameters: ventilation rate,
mixing factor, saturation factor, loss factors, container sizes, working years, operating and exposure
days, formaldehyde concentration in the hydraulic fracturing fluid, formaldehyde concentration in the
additive, and use rate of hydraulic fracturing. The Agency used the outputs from a Monte Carlo
simulation with 100,000 iterations and the Latin Hypercube sampling method in @Risk to calculate
exposure concentrations for this OES.
C.7.1 Model Equations
TableApx C-14 provides the models and associated variables used to calculate occupational exposures
for each exposure point within each iteration of the Monte Carlo simulation. EPA used these
occupational exposures to develop a distribution of exposure outputs for the use of formaldehyde in
oilfield well production OES. The Agnecy assumed that the same worker performed each exposure
activity resulting in a total exposure duration of up to 8 hours per day. The variables used to calculate
each of the following exposure concentrations and durations include deterministic or variable input
parameters, known constants, physical properties, conversion factors, and other parameters. The values
for these variables are provided in the next section. The Monte Carlo simulation calculated an 8-hour
TWA exposure concentration for each iteration using the exposure concentration and duration associated
with each activity and assuming exposures outside the exposure activities were zero. EPA then selected
50th percentile and 95th percentile values to estimate the central tendency and high-end exposure
concentrations, respectively.
Table Apx C-14. Models and Variables Applied for Exposure Points in the Use of Formaldehyde
in Oilfield Well Production
Exposure Point
Model(s) Applied
Variables Used
Exposure point A: Transfer
operation exposures during
container unloading
EPA/OPPT Mass Balance
Inhalation Model with vapor
generation rate from EPA/OAQPS
AP-42 Loading Model (Appendix
c.i)
Vapor generation rate: FFAadditive; VP:
Fsat; MW; Vcont, R',T',
RATEfm_smaucont, RATEventnation,
F'mixing3 Vm
Exposure Duration: RATEunioad
Exposure point B: Exposure
to formaldehyde during
container cleaning activities
EPA/OPPT Mass Balance
Inhalation Model with vapor
generation rate from EPA/OPPT
Mass Transfer Coefficient Model,
based on air speed (Appendix C.I)
Vapor Generation Rate: FFA_additive; VP:
Fsatj MW; Vcont; R; T; RATEunioad;
RATEventuation, Fmixing, Vitl.
D container _opening
Exposure duration: Vsmall cont;
RATEunload
Exposure point C: Exposure
to formaldehyde during
equipment cleaning activities
EPA/OPPT Mass Balance
Inhalation Model with vapor
generation rate from EPA/OPPT
Mass Transfer Coefficient Model,
based on air speed (Appendix C.I)
Vapor Generation Rate: FFA_additive; VP;
Fsat j MW; Vcont; R; T; RATEunioad;
RATEventnation, Fmixing, Vitl.
^equipment _opening
C.7.2 Model Input Parameters
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Table summarizes the model parameters and their values for the use of formaldehyde for oilfield well production Monte Carlo simulation.
Additional explanations of EPA's selection of the distributions for each parameter are provided after this table.
TableApx C-15. Summary of Parameter Values and Distributions Used in the Use of Formaldehyde for Oilfield Well Production
Models
Input Parameter
Symbol
Unit
Deterministic
Values
Uncertainty Analysis Distribution Parameters
Rationale/Basis
Lower
Bound
Upper
Bound
Mode
Distribution
Type
Working Years
WY
years
36
10.4
44
36
Triangular
See Section C.7.11
Ventilation Rate
AVI TEventilation
ft3/min
132,000
132,000
237,600
-
Uniform
See Section C.7.9
Mixing Factor
Fmixing
dimensionles
s
0.5
0.1
1
0.5
Triangular
See Section C.7.10
Saturation Factor Unloading
Fsat
kg/kg
0.5
0.5
1.45
0.5
Triangular
See Section C.7.8
Days Exposed per Year (37%
Formalin Adjustment)
EFformalin
days/year
11
1
250
-
Discrete
See Section C.7.2
Days Exposed per Year (60%
Formaldehyde Concentration Cap)
EF60
days/year
11
1
250
-
Discrete
See Section C.7.2
Annual Use Rate of Fracturing
Fluids containing Formaldehyde
(37% Formalin Adjustment)
Qsite_yr_formalin
gal/site-year
9,136,382
513
136,744,054
Discrete
See Section C.7.2
Annual Use Rate of Fracturing
Fluids containing Formaldehyde
(60% Formaldehyde Concentration
Cap)
Qsitejyr 60
gal/site-year
9,228,444
513
136,744,054
Discrete
See Section C.7.2
Mass Fraction of Formaldehyde in
Hydraulic Fracturing Additive
FfA additive
kg/kg
-
-
-
-
Discrete
See Section C.7.2
Mass Fraction of Formaldehyde in
Hydraulic Fracturing Fluid
FFA^fracturing fluid
kg/kg
-
-
-
-
Discrete
See Section C.7.2
Container Size for Drums
Vdrum
gal/cont
55
20
100
55
Triangular
See Section C.7.4
Container Size for Totes
Vtote
gal/cont
550
100
1,000
550
Triangular
See Section C.7.4
Container Size for Tank Trucks
Vtank truck
gal/cont
5,000
1,000
10,000
5,000
Triangular
See Section C.7.4
Drum/Tote Unloading Rate
RA TEdrum
containers/hr
20
-
-
-
-
See Section C.7.5
Tank Truck Unloading Rate
RA TEtruck
containers/hr
2
-
-
-
-
See Section C.7.5
Diameter of Container Opening
F)container opening
cm
5.08
-
-
-
-
See Section C.7.6
Diameter of Equipment Opening
F)equip opening
cm
92
-
-
-
-
See Section C.7.6
Air Speed
RA TEair speed
ft/min
440
-
-
-
-
See Section C.7.7
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Input Parameter
Symbol
Unit
Deterministic
Values
Uncertainty Analysis Distribution Parameters
Rationale/Basis
Lower
Bound
Upper
Bound
Mode
Distribution
Tvpe
Activity C (Equipment Cleaning)
Operating Hours
hc
hours/day
4
—
—
—
—
See Section C.7.12
Formaldehyde Molar Volume
Vm
L/mol
24.45
-
-
-
-
Molar volume at STP
Formaldehyde Molecular Weight
MW
g/mol
30.026
From the 2020 Final Scope
of the Risk Evaluation for
Formaldehyde; CASRN 50-
00-0 (U.S. EPA. 2020c)
Hours exposed per day
ED
hrs/day
8
Assuming a full 8-hour
shift
Lifetime years
LT
years
78
-
-
-
-
Average lifetime years
Averaging time over a lifetime
(chronic)
AT a
hours
683,280
-
-
-
-
Converted lifetime years to
hours
Assessed Vapor Pressure
VP
Torr
1.3
-
-
-
-
Vapor pressure of formalin
at 20 °C
Gas Constant
R
L*torr/mol-K
62.36367
-
-
-
-
Universal gas constant
Temperature
T
K
298
-
-
-
-
Standard temperature
Pressure
P
ton-
760
-
-
-
-
Standard pressure
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C.7.3 FracFocus Parameters
EPA utilized two different approaches for the analysis of formaldehyde-specific data reported to the
FracFocus 3.0 database (GWPC and IOGCC. 2022). The first approach only included data which
reported a concentration of 37 percent formaldehyde in both the hydraulic fracturing fluid and additive.
The second approach included all of the formaldehyde-containing FracFocus data but adjusted the mass
concentration data by multiplying each concentration by 60 percent. The motivation for each of these
approaches was to adjust for reporters potentially reporting the mass concentration of formalin rather
than formaldehyde for the mass concentration data. These approaches each protect against
unrealistically high reported concentrations of formaldehyde {i.e., 100%) skewing the exposure results.
EPA modeled the mass fraction of formaldehyde in the hydraulic fracturing fluid and additive using
discrete distributions based on data obtained from FracFocus 3.0 for the sites that reported using
fracturing fluids containing formaldehyde (GWPC £ 2022). The distribution was calculated
using an equal probability for each of the submissions from FracFocus 3.0. The discrete values for the
mass fraction of formaldehyde in hydraulic fracturing additive ranged from 1,00/10 5 to 100 percent.
The discrete values for the mass fraction of formaldehyde in hydraulic fracturing fluid ranged from
6.91 xl0~16 to 1.61 percent.
EPA modeled the operating days per year using a discrete distribution with a minimum of 1 day per year
and an upper bound of 250 days per year. Discrete data points on the number of operating days were
taken from FracFocus 3.0 for the sites that reported using fracturing fluids containing formaldehyde
(GWPC and IOGCC. 2022). The upper bound of the distribution assumes that no single worker will
work more than 250 days per year.
EPA modeled the annual use rate of fracturing fluids containing formaldehyde using a discrete
distribution based on data obtained from FracFocus 3.0 for the sites that reported using fracturing fluids
containing formaldehyde (GWPC and IOGCC. 2022). The distribution was calculated using an equal
probability for each of the submissions from FracFocus 3.0. The discrete values for the annual use rate
of fracturing fluids containing formaldehyde ranged from 513 to 136,744,054 gal/site-yr.
C.7.4 Container Volume
The ESD on Chemicals Used in Hydraulic Fracturing states that hydraulic fracturing chemicals are
received in drums or bulk containers ( 22d). Additionally, due to the high volume of
throughput reported in the FracFocus data, tank trucks were also assumed to be used to receive hydraulic
fracturing additives (GWPC and IOGCC. 2022). Therefore, EPA modeled container size using three
different triangular distributions: one for drums, one for totes, and one for tank trucks. The distribution
for drums ranged from 20 to 100 gallons of liquid with a mode of 55 gallons. The distribution for totes
ranged from 100 to 1,000 gallons of liquid with a mode of 550 gallons. The distribution for tank trucks
ranged from 1,000 to 10,000 gallons of liquid with a mode of 5,000 gallons. Each of these distributions
is based on the ChemSTEER User Guide ( 3) default volume distributions for drums,
bulk containers, and tank trucks.
EPA recognizes that in the modeled results for this OES, the maximum values for calculated throughput
of containers unloaded per year is an unrealistic result. This is a consequence of the wide range of
reported mass concentration values for formaldehyde in both the hydraulic fracturing fluid and additive.
Since the container throughput is calculated based on the ratio between these two concentrations,
unrealistic results are unavoidable at the extremes.
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C.7.5 Container Fill Rate
The ChemSTEER User Guide ( ) provides a typical fill rate of 20 containers per hour
for drums and totes. The typical fill rate for tank trucks is two containers per hour.
C.7.6 Diameters of Openings
The ChemSTEER User Guide (U.S. EPA. 2015b) provides a single diameter of container openings as
5.08 cm. The ChemSTEER User Guide ( 2015b) provides a single diameter of equipment
openings as 92 cm.
C.7.7 Air Speed
The ChemSTEER User Guide (U.S. EPA. 2015b) provides a single air speed of 440 ft/min for outdoor
activities.
C.7.8 Saturation Factor
The Chemical Engineering Branch Manual for the Preparation of Engineering Assessments, Volume 1
(CEB Manual) indicates that during splash filling, the saturation concentration was reached or exceeded
by misting with a maximum saturation factor of 1.45 ( ). The CEB Manual indicates
that saturation concentration for bottom filling was expected to be about 0.5 ( ). The
underlying distribution of this parameter is not known; therefore, EPA assigned a triangular distribution
based on the lower bound, upper bound, and mode of the parameter. Because a mode was not provided
for this parameter, the Agency assigned a mode value of 0.5 for bottom filling as bottom filling
minimizes volatilization ( ). This value also corresponds to the typical value provided in
the ChemSTEER User Guide for the EPA/OAQPS AP-42 Loading Model ( j).
C.7.9 Ventilation Rate
The CEB Manual ( ) indicates general outdoor ventilation rates in industry range from
132,000 to 237,600 ftVmin in outdoor conditions. The underlying distribution of this parameter is not
known; therefore, EPA assigned a uniform distribution, since a uniform distribution is completely
defined by range of a parameter.
C.7.10 Mixing Factor
The CEB Manual (U.S. EPA. 1991a) indicates mixing factors may range from 0.1 to 1, with' 1
representing ideal mixing. The CEB Manual references the 1988 ACGIH Ventilation Handbook, which
suggests the following factors and descriptions: 0.67 to 1 for best mixing; 0.5 to 0.67 for good mixing;
0.2 to 0.5 for fair mixing; and 0.1 to 0.2 for poor mixing (I v « « \ l l,.). The underlying distribution
of this parameter is not known; therefore, EPA assigned a triangular distribution based on the defined
lower and upper bound and estimated mode of the parameter. The mode for this distribution was not
provided; therefore, the Agency assigned a mode value of 0.5 based on the typical value provided in the
ChemSTEER User Guide for the EPA/OPPTMass Balance Inhalation Model ( b).
C.7.11 Worker Years
EPA has developed a triangular distribution for working years. EPA has defined the parameters of the
triangular distribution as follows:
• Minimum value: BLS CPS tenure data with current employer as a low-end estimate of the
number of lifetime working years: 10.4 years;
• Mode value: The 50th percentile tenure data with all employers from SIPP as a mode value for
the number of lifetime working years: 36 years; and
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• Maximum value: The maximum average tenure data with all employers from SIPP as a high-end
estimate on the number of lifetime working years: 44 years.
This triangular distribution has a 50th percentile value of 31 years and a 95th percentile value of 40
years. EPA uses these values for central tendency and high-end ADC and LADC calculations,
respectively.
The BLS (U ,S. BLS. 2014) provides information on employee tenure with current employer obtained
from the CPS, which is a monthly sample survey of about 60,000 households that provides information
on the labor force status of the civilian non-institutional population age 16 and over. CPS data are
released every 2 years. The data are available by demographics and by generic industry sectors but are
not available by NAICS codes.
The U.S. Census' (1; S Census Bureau. 2019a) SIPP provides information on lifetime tenure with all
employers. SIPP is a household survey that collects data on income, labor force participation, social
program participation and eligibility, and general demographic characteristics through a continuous
series of national panel surveys of between 14,000 and 52,000 households ( isus Bureau. 2019b).
EPA analyzed the 2008 SIPP Panel Wave 1, a panel that began in 2008 and covers the interview months
of September 2008 through December 2008 ( 'ensus Bureau. 2019a. b). For this panel, lifetime
tenure data are available by Census Industry Codes, which can be crosswalked with NAICS codes.
SIPP data include fields for the industry in which each surveyed, employed individual works
(TJBIND1), worker age (TAGE), and years of work experience with all employers over the surveyed
individual's lifetime.5 Census household surveys use different industry codes than the NAICS codes
used in its firm surveys, so these were converted to NAICS using a published crosswalk (Census
Bureau, 2012b). EPA calculated the average tenure for the following age groups: (1) workers aged 50
and older, (2) workers aged 60 and older, and (3) workers of all ages employed at time of survey. EPA
used tenure data for age group "50 and older" to determine the high-end lifetime working years, because
the sample size in this age group is often substantially higher than the sample size for age group "60 and
older." For some industries, the number of workers surveyed, or the sample size, was too small to
provide a reliable representation of the worker tenure in that industry. Therefore, EPA excluded data
where the sample size is less than five from the analysis.
Table Apx C-16. Overview of Average Worker Tenure from U.S. Census SIPP (Age Group 50+)
summarizes the average tenure for workers aged 50 and older from SIPP data. Although the tenure may
differ for any given industry sector, there is no significant variability between the 50th and 95th
percentile values of average tenure across manufacturing and non-manufacturing sectors.
Table Apx C-16. Overview of Average Worker Tenure from U.S. Census SIPP (Age Group 50+)
Industry Sectors
Working Years
Average
50th
Percentile
95th
Percentile
Maximum
Manufacturing sectors (NAICS 31-33)
35.7
36
39
40
Non-manufacturing sectors (NAICS 42-81)
36.1
36
39
44
Source: ("U.S. Census Bureau. 2019a).
5 To calculate the number of years of work experience EPA took the difference between the year first worked
(TMAKMNYR) and the current data year {i.e., 2008). The Agency then subtracted any intervening months when not working
(ETIMEOFF).
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Industry Sectors
Working Years
Average
50th
Percentile
95th
Percentile
Maximum
Note: Industries where sample size is less than five are excluded from this analysis.
BLS CPS data provides the median years of tenure that wage and salary workers had been with their
current employer. Table Apx C-17 presents CPS data for all demographics (men and women) by age
group from 2008 to 2012. To estimate the low-end value on number of working years, EPA uses the
most recent (2014) CPS data for workers aged 55 to 64 years, which indicates a median tenure of 10.4
years with their current employer. The use of this low-end value represents a scenario where workers are
only exposed to the chemical of interest for a portion of their lifetime working years, as they may
change jobs or move from one industry to another throughout their career.
Table Apx C-17. Median Years of Tenure with Current Employer by Age Group
Age
January 2008
January 2010
January 2012
January 2014
16 years and over
4.1
4.4
4.6
4.6
16 to 17 years
0.7
0.7
0.7
0.7
18 to 19 years
0.8
1.0
0.8
0.8
20 to 24 years
1.3
1.5
1.3
1.3
25 years and over
5.1
5.2
5.4
5.5
25 to 34 years
2.7
3.1
3.2
3.0
35 to 44 years
4.9
5.1
5.3
5.2
45 to 54 years
7.6
7.8
7.8
7.9
55 to 64 years
9.9
10.0
10.3
10.4
65 years and over
10.2
9.9
10.3
10.3
C.7.12 Exposure Activity Hours
The ChemSTEER User Guide (U.S. EPA. 2015b) provides a single duration of 4 hours/day for
equipment cleaning of multiple vessels. The exposure duration for the container cleaning and container
unloading activities was calculated using EquationApx C-6 below:
EquationApx C-6.
Where:
hA
Ncont_unload_yr
EF
RATEunload
hA =
N,
cont_unload_yr
EF * RATE,
unload
Exposure duration during container unloading [hrs/day]
Annual number of containers unloaded [cont/site-yr]
Exposure frequency [days/yr]
Container unloading rate [cont/hr]
Page 217 of 313
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€.8 Tank Truck and Railcar Loading and Unloading Release and
Inhalation Exposure Model Methodology
This appendix presents the modeling approach and model equations used in the Tank Truck and Railcar
Loading and Unloading Release and Inhalation Exposure Model. The model was developed through
review of relevant literature and consideration of existing EPA exposure models. The model approach is
a generic inhalation exposure assessment at industrial facilities that is applicable for any volatile
chemical with the following COUs:
• Manufacture (loading of chemicals into containers);
• Processing as a reactant/intermediate (unloading of chemicals);
• Processing into formulation, mixture, or reaction products;
• Import (repackaging); and
• Other similar COUs at industrial facilities (e.g., industrial processing aid).
As an example, formaldehyde at a manufacturing facility is expected to be packaged and loaded into a
container before distributing to another industrial processing or use site (e.g., formulation sites, sites
using Formaldehyde as an intermediate, and sites using formaldehyde as a processing aid). At the
industrial processing or use site, formaldehyde is then unloaded from the container into a process vessel
before being incorporated into a mixture, used as a chemical intermediate, or otherwise processed/used.
For the model, EPA assumes formaldehyde is unloaded into tank trucks and railcars and transported and
distributed in bulk. EPA also assumes the chemical is handled as a pure substance (100 percent
concentration).
Because formaldehyde is volatile (vapor pressure above 0.01 torr at room temperature), fugitive
emissions may occur when formaldehyde is loaded into or unloaded from a tank truck or railcar. Sources
of these emissions include
• Displacement of saturated air containing Formaldehyde as the container/truck is filled with
liquid;
• Emissions of saturated air containing Formaldehyde that remains in the loading arm, transfer
hose, and related equipment; and
• Emissions from equipment leaks from processing units such as pumps, seals, and valves.
These emissions result in subsequent exposure to workers involved in the transfer activity. The
following subsections address these emission sources.
C.8.1 Displacement of Saturated Air Inside Tank Truck and Railcars
For screening-level assessments, EPA typically uses the EPA/OAQPS AP-42 Loading Model to
conservatively assess exposure during container unloading activities ( ). The model
estimates release to air from the displacement of air containing chemical vapor as a container/vessel is
filled with liquid ( ). The model assumes the unloading activity displaces an air volume
equal to the size of the container, and that displaced air is either 50 percent or 100 percent saturated with
chemical vapor ( •).
Process units at facilities that manufacture Formaldehyde as a primary product; use Formaldehyde as a
reactant or manufacture Formaldehyde as a product or co-product; or are located at a plant that is a
major source of hazardous air pollutants (HAPs) as defined in section 112(a) of the Clean Air Act are
required to install and operate a vapor capture system and control device (or vapor balancing system) for
loading/unloading operations ( ). Therefore, EPA expects the majority of industrial
facilities to use a vapor balance system to minimize fugitive emissions when loading and unloading tank
Page 218 of 313
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trucks and railcars. As such, vapor losses from displacement of air is likely mitigated by the use of such
systems. Actual fugitive emissions are likely limited to any saturated vapor that remain in the hose,
loading arm, or related equipment after being disconnected from the truck or rail car. This emission
source is addressed in the next subsection.
C.8.2 Emissions of Saturated Air inside Tank Truck and Railcars
After loading is complete, transfer hoses and/or loading arms are disconnected from tank trucks and
railcars. Saturated air containing the chemical of interest that remains in transfer equipment may be
released to air, presenting a source of fugitive emissions. The quantity of Formaldehyde released will
depend on concentration in the vapor and the volume of vapor in the loading arm/hose/piping.
TableApx C-18 presents the dimensions for several types of loading systems according to an OPW
Engineered Systems catalog (OPW Engineered Systems. 2014). OPW Engineered Systems specializes
in the engineering, designing, and manufacturing of systems for loading and unloading a wide range of
materials including petroleum products, liquefied gases, asphalt, solvents, and hazardous and corrosive
chemicals. These systems include loading systems, swivel joints, instrumentation, quick and dry-
disconnect systems, and safety breakaways. Based on the design dimensions, the table presents the
calculated total volume of loading arm/system and assumes the volume of vapor containing
Formaldehyde equals the volume of the loading arm/system.
EPA expects formaldehyde is expected to be delivered in either tank trailers or tank cars. Therefore, the
Agency modeled the central tendency scenario as tank truck loading/unloading. EPA modeled the high-
end scenario as railcar loading/unloading since railcars are larger and more likely to use longer transfer
arms (and thus represent a higher exposure potential than tank trucks). To estimate the high-end transfer
arm volume, EPA calculated the 95th percentile of the OPW Engineered Systems loading arms
volumetric data resulting in a high-end value of 17.7 gallons. For the central tendency tank truck
scenario, the Agency assumed a 2-inch diameter, 12-ft long transfer hose. This hose has a volume of 2.0
gallons.
Once the volume is known, the emission rate, Et (g/s), can be calculated as follows:
EquationApx C-5.
_fx MW x 3,786.4 xVhxXxVP
tdisconnect X T X R X 3,600 X 760
Default values for Equation Apx C-5 can be found in Table Apx C-19.
Page 219 of 313
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Table Apx C-18. Example Dimension and Volume of Loading Arm/Transfer System
OPW Engineered Svstems Transfer Arm
Length of Loading Arm/Connection
(in)"
Volume, Vh (gal)h
2-Ineh
3-Inch
4-Ineh
6-Ineh
2-Inch
3-Ineh
4-Ineh
6-Ineh
Unsupported Boom-Type Bottom Loader
149.875
158.5
165.25
191.75
2.0
4.9
9.0
23.5
"A" Frame Loader M-32-F
153.75
159.75
164.5
N/A
2.1
4.9
8.9
N/A
"A" Frame Hose Loader AFH-32-F
180.75
192.75
197.5
N/A
2.5
5.9
10.7
N/A
CWH Series Counterweighted Hose Loader
N/A
N/A
309
N/A
N/A
N/A
16.8
N/A
Spring Balanced Hose Loader SRH-32-F
204.75
216.75
221.5
N/A
2.8
6.6
12.0
N/A
Spring Balanced Hose Loader LRH-32-F
N/A
270
277.625
N/A
N/A
8.3
15.1
N/A
Top Loading Single Arm Fixed Reach
201.75
207.75
212.5
N/A
2.7
6.4
11.6
N/A
Top Loading Scissor Type Arm
197.875
206.5
213.25
N/A
2.7
6.3
11.6
N/A
Supported Boom Arm B-32-F
327.375
335
341.5
N/A
4.5
10.3
18.6
N/A
Unsupported Boom Arm GT-32-F
215.875
224.5
231.25
N/A
2.9
6.9
12.6
N/A
Slide Sleeve Arm A-32F
279
292.5
305.125
N/A
3.8
9.0
16.6
N/A
1 lose u iihoni transfer arm
Hose (LPA judgment;
120
1.0
Source: (OPW Engineered Svstems. 2014).
" Total length includes length of piping, connections, and fittings.
h Calculated based on dimension of the transfer hose/connection, I), = nrl, (converted from cubic inch to gallons).
Table Apx C-19. Default Values for Calculating Emission Rate of Formaldehyde from
Transfer/Loading Arm
Parameter
Parameter Description
Default Value
Unit
Et
Emission rate of chemical from
transfer/loading system
Calculated from model equation
g/s
f
Saturation factora
1
dimensionless
MW
Molecular weight of the chemical
30.026
g/mol
vh
Volume of transfer hose
See Table_Apx C-18
gallons
r
Fill rate a
2 (tank truck)
1 (railcar)
containers/hr
tdisconnect
Time to disconnect hose/couplers (escape of
saturated vapor from disconnected hose or
transfer arm into air)
0.25
hr
X
Vapor pressure correction factor
1
dimensionless
VP
Vapor pressure of formalin
1.3
ton-
T
Temperature
298
IC
R
Universal gas constant
82.05
atm-cm3/gmol-K
a Saturation factor and fill rate values are based on established EPA/OPPT release and inhalation exposure assessment
methodologies.
Page 220 of 313
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C.8.3 Emissions from Leaks
During loading/unloading activities, emissions may also occur from equipment leaks from valves,
pumps, and seals. Per EPA's Chapter 5: Petroleum Industry of AP-42 (U.S. EPA. 2015a) and EPA's
Protocol for Equipment Leak Emission Estimates ( |c), the following equation can be used
to estimate emission rate El, calculated as the sum of average emissions from each process unit:
EquationApx C-6.
Z 1,000
(^x^xJVjx —
Parameters for calculating equipment leaks using Equation Apx C-6 can be found in TableApx C-20.
TableApx C-20. Parameters for Calculating Emission Rate of Formaldehyde from Equipment
Leaks
Parameter
Parameter Description
Default Value
Unit
El
Emission rate of chemical from equipment leaks
Calculated from model
equation
g/s
Fa
Applicable average emission factor for the equipment
type
See Section C.8.4
kg/hr-source
WFtoc
Average weight fraction of chemical in the stream
1
Dimensionless
N
Number of pieces of equipment of the applicable
equipment type in the stream
See Section C.8.4
Source
To estimate emission leaks using this modeling approach, EPA modeled a central tendency loading rack
scenario using tank truck loading/unloading and a high-end loading rack scenario using railcar
loading/unloading. EPA used engineering judgment to estimate the type and number of equipment
associated with the loading rack in the immediate vicinity of the loading operation. EPA assumes at least
one worker will be near the loading rack during the entire duration of the loading operation.
Table Apx C-20 presents the average emission factor for each equipment type, based on the synthetic
organic chemical manufacturing industry (SOCMI) emission factors as provided by EPA's 1995
Protocol ( :) and the likely number of pieces of each equipment used for each chemical
loading/unloading activity, based on EPA's judgment. Note these emission factors are for emission rates
of total organic compound emission and are assumed to be applicable to formaldehyde. In addition,
these factors are most valid for estimating emissions from a population of equipment and are not
intended to be used to estimate emissions for an individual piece of equipment over a short period of
time.
C.8.4 Exposure Estimates
The vapor generation rate, G, or the total emission rate over time, can be calculated by aggregating
emissions from all sources:
• During the transfer period, emissions are only due to leaks, with emission rate G = EL.
• After transfer, during the disconnection of the hose(s), emissions are due to both leaks and
escape of saturated vapor from the hose/transfer arm with emission rate G = ET + EL.
The vapor generation rate can then be used with the EPA Mass Balance Inhalation Model to estimate
worker exposure during loading/unloading activities ( b). That model estimates the
exposure concentration using Equation Apx C-7 and the default parameters found in Table Apx C-21
Page 221 of 313
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( 2015b). Table_Apx C-21 presents exposure estimates for Formaldehyde using this approach.
These estimates assume one unloading/loading event per day and Formaldehyde is loaded/unloaded at
100 percent concentration. The loading operation occurs in an outdoor area with minimal structure, with
wind speeds of 9 mph (central tendency) or 5 mph (high-end).
EquationApx C-7.
r
_ ^V
m — v
vm
TableApx C-21. Parameters for Calculating Exposure Concentration Using the EPA/OPPT Mass
Balance Model
Parameter
Parameter Description
Default Value
Unit
Cm
Mass concentration of chemical in air
Calculated from model equation
mg/m3
Cv
Volumetric concentration of chemical
in air
Calculated as the lesser of:
170,000xTxG 1,000,000 XXXVP
MWxQxk OT 760
ppm
T
Temperature of air
298
K
G
Vapor generation rate
El during transfer period
Et+El after transfer/during
disconnection of hose/transfer arm
g/s
MW
Molecular weight of the chemical
30.026
g/mol
Q
Outdoor ventilation rate
237,600 (central tendency)
26,400 X (60 X 528Q) (high-end)
ft3/min
vz
Air speed
440
ft/min
k
Mixing factor
0.5
dimensionless
X
Vapor pressure correction factor
1
dimensionless
VP
Vapor pressure of the pure chemical
1.3
torr
vm
Molar volume
24.45 @ 25°C, 1 atm
L/mol
EPA calculated 8-hour TWA exposures as shown in Equation Apx C-8. The 8-hour TWA exposure is
the weighted average exposure during an entire 8-hour shift, assuming zero exposures during the
remainder of the shift. EPA assumed one container is loaded/unloaded per shift: one tank truck per shift
for the central tendency scenario and one railcar per shift for the high-end scenario.
Equation Apx C-8.
( Cm(leak only) ^ Q^event ~ tdisconnect) \^m(leak and hose) ^ tdisconnect) ) ^ ^cont
8-hr TWA = -
8
Where:
Cm (leak only)
Cmfleak and hose)
Airborne concentration (mass-based) due to leaks during unloading while
hose connected (mg/m3)
Airborne concentration (mass-based) due to leaks and displaced air during
hose disconnection (mg/m3)
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hevent = Exposure duration of each loading/unloading event (hr/event); calculated
as the inverse of the fill rate, r : 0.5 hr/event for tank trucks and 1 hr/event
for railcars
hshift = Exposure duration during the shift (hr/shift); calculated as hevent x Ncont-
0.5 hr/shift for tank trucks and 1 hr/shift for railcars
tdisconnect = Time duration to disconnect hoses/couplers (during which saturated vapor
escapes from hose into air) (hr/event)
Ncont = Number of containers loaded/unloaded per shift (event/shift); assumed one
tank truck per shift for central tendency scenario and one railcar per shift
for high-end scenario
TableApx C-22. Calculated Emission Rates and Resulting Exposures from the Tank Truck and
Scenario
El
(g/s)
Et
(g/s)
El+Et
(g/s)
Cm
(Leaks Only)
(mg/m3)
Cm
(Leaks and Hose Vapor)
(mg/m3)
8-Hour TWA
(mg/m3)
Central Tendency
0.044
1.73E-05
0.044
0.76
0.76
0.047
High-End
0.049
1.56E-04
0.049
1.52
1.53
0.19
€.9 Generic Model for Central Tendency and High-End Inhalation
Exposure to Total and Respirable Particulates Not Otherwise
Regulated (PNQR)
The Generic Model for Central Tendency and High-End Inhalation Exposure to Total and Respirable
Particulates Not Otherwise Regulated (PNOR) ( ) estimates worker inhalation exposure
to total and respirable solid particulates using personal breathing zone Particulate, Not Otherwise
Regulated (PNOR) monitoring data from OSHA's Chemical Exposure Health Data (CEHD) dataset.
The CEHD data provides PNOR exposures as 8-hour TWAs by assuming exposures outside the
sampling time are zero, and the data also include facility NAICS code information for each data point.
To estimate particulate exposures for relevant OESs, EPA used the 50th and 95th percentiles of
respirable PNOR values for applicable NAICS codes as the central tendency and high-end exposure
estimates, respectively.
EPA assumed formaldehyde is present in particulates at the same mass fraction as in the bulk solid
material. Therefore, EPA calculates the 8-hour TWA exposure to formaldehyde present in dust and
particulates using the following equation:
ChCHOMv-TWA — CpNOR,8hr-TWA X FHCHO
Where:
CHCHo,ahr-TWA = 8-hour TWA exposure to Formaldehyde [mg/m3]
CPNOR,ahr-TWA = 8-hour TWA exposure to PNOR [mg/m3]
Fhcho = Mass fraction of Formaldehyde in bulk material [mg/mg]
Table Apx C-23 provides a summary of the associated NAICS code, PNOR 8-hour TWA exposures.
Page 223 of 313
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Table Apx C-23. Total PNOR Default Concentrations
Industry Group
No. of
Samples
Percentile of
OSHA PNOR
PEL
Total PNOR Default
- Central Tendency
(50th percentile)
Total PNOR Default
- High-End (95th
percentile or PEL)
Percentile
mg/m3
mg/m3
11 - Agriculture, Forestry, Fishing
and Hunting
31
79%
2.8
15
56 - Administrative and Support
and Waste Management and
Remediation Services
130
79%
2.5
15
C.10 Dermal Exposure Model Methodology
This appendix presents the modeling parameters used to estimate occupational dermal exposures. This
method was developed through review of relevant literature and consideration of existing exposure
models, such as EPA/OPPT models.
C.10.1 Model Input Parameters
The modelling equation approach for occupational dermal exposures is outlined in Section 2.6. The
dermal load (Qu) is the quantity of chemical on the skin after the dermal contact event. This value
represents the quantity remaining after the bulk chemical formulation has fallen from the hand that
cannot be removed by wiping the skin (e.g., the film that remains on the skin). To estimate the dermal
load from each activity, EPA used data from references cited by EPA's September 2013 engineering
policy memorandum: "Updating CEB's Method for Screening-Level Assessments of Dermal Exposure"
(U.S. EPA.! ). The contact event modeled for the formaldehyde OESs was routine and incidental
contact with liquids (e.g., maintenance activities, manual cleaning of equipment, filling drums,
connecting transfer lines, sampling, and bench-scale liquid transfers). For this event, the memorandum
uses values of 0.7 to 2.1 mg/cm2-event for routine liquid contact. EPA uses the maximum value of the
range from the memorandum to estimate high-end dermal loads. The memorandum did not provide
recommended values for a central tendency dermal loading estimate. Therefore, EPA analyzed data
from EPA's technical report^ Laboratory Method to Determine the Retention of Liquids on the Surface
of the Hands ( b) that served as the basis for the liquid dermal loading values provided in
the 2013 memorandum. To estimate central tendency liquid dermal loading values, EPA used the 50th
percentile of the dermal loading results for the routine liquid contact activity. The 50th percentile value
was 1.4 mg/cm2-event for routine/incidental contact with liquids.
Page 224 of 313
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Appendix D CROSSWALK OF NAICS CODES TO OES FOR OSHA CEHD DATA ANALYSIS
Table A
)x D-l. Mapping of NAICS Codes to OES
NAICS
NAICS Description
Mapped OES
Basis
111998
All Other Miscellaneous Crop
Farming
Unknown
This industry primarily includes operations that include growing different
crops not included in other agricultural NAICS codes. The Agricultural use
OES fits best for this industry as formaldehyde is likely used in fertilizer
applied to crop fields.
112120
Dairy Cattle and Milk
Production
Unknown
Sector 11, which this NAICS code falls under, is defined as "Agriculture,
Forestry, Fishing and Hunting." A specific use of formaldehyde within the
scope of this risk evaluation in dairy cattle and milk production has not been
identified.
112130
Dual-Purpose Cattle
Ranching and Farming
Unknown
Sector 11, which this NAICS code falls under, is defined as "Agriculture,
Forestry, Fishing and Hunting." A specific use of formaldehyde within the
scope of this risk evaluation in dual-purpose cattle ranching and farming has
not been identified.
112310
Chicken Egg Production
Unknown
Sector 11, which this NAICS code falls under is defined as "Agriculture,
Forestry, Fishing and Hunting." A specific use of formaldehyde within the
scope of this risk evaluation in chicken egg production has not been
identified.
112340
Poultry Hatcheries
Unknown
Sector 11, which this NAICS code falls under, is defined as "Agriculture,
Forestry, Fishing and Hunting." A specific use of formaldehyde within the
scope of this risk evaluation in poultry hatcheries has not been identified.
112511
Finfish Farming and Fish
Hatcheries
Unknown
Sector 11, which this NAICS code falls under, is defined as "Agriculture,
Forestry, Fishing and Hunting." A specific use of formaldehyde within the
scope of this risk evaluation in finfish farming and fish hatcheries has not
been identified.
115111
Cotton Ginning
Unknown
Sector 11, which this NAICS code falls under, is defined as "Agriculture,
Forestry, Fishing and Hunting." A specific use of formaldehyde within the
scope of this risk evaluation in cotton ginning has not been identified.
115116
Farm Management Services
Unknown
Sector 11, which this NAICS code falls under, is defined as "Agriculture,
Forestry, Fishing and Hunting." A specific use of formaldehyde in farm
management services within the scope of this risk evaluation has not been
identified.
Page 225 of 313
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NAICS
NAICS Description
Mapped OES
Basis
115210
Support Activities for Animal
Production
Unknown
Sector 11, which this NAICS code falls under, is defined as "Agriculture,
Forestry, Fishing and Hunting." A specific use of formaldehyde in support
activities for animal production within the scope of this risk evaluation has
not been identified.
211130
Natural Gas Extraction
Use of formaldehyde for
oilfield well production
This industry includes the extraction and production of natural gas from
wells, and the recovery of liquid hydrocarbons from oil and gas field gases.
The Use of formaldehyde for oilfield well production OES best matches
these processes.
212324
Kaolin and Ball Clay Mining
Unknown- Combustion sources
EPA is not aware of an intentional use of formaldehyde for Kaolin and Ball
Clay Mining and the industry of mining was not identified through CDR.
("NICNAS, 2006) indicated emissions from mining due to combustion
sources such as vehicle exhaust, boilers, blating, and power generation.
Therefore, EPA expects these exposures are likely the sole result of
combustion sources.
213112
Support Activities for Oil and
Gas Operations
Use of formaldehyde for
oilfield well production
Industry is similar in function to the "Natural Gas Extraction" NAICS code.
The Use of formaldehyde for oilfield well production OES best matches
these processes.
221111
Hydroelectric Power
Generation
Unknown
A specific use of formaldehyde within the scope of this risk evaluation in
hydroelectric power generation has not been identified.
236220
Commercial and Institutional
Building Construction
Installation and demolition of
formaldehyde based furnishings
and building/construction
materials in residential, public,
and commercial buildings, and
other structures
Building and construction materials OES is closest match with this NAICS
code.
237310
Highway, Street, and Bridge
Construction
Installation and demolition of
formaldehyde based furnishings
and building/construction
materials in residential, public,
and commercial buildings, and
other structures
Building and construction materials OES is closest match with this NAICS
code.
Page 226 of 313
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NAICS
NAICS Description
Mapped OES
Basis
238130
Framing Contractors
Installation and demolition of
formaldehyde based furnishings
and building/construction
materials in residential, public,
and commercial buildings, and
other structures
Framing contractors engage in wood and steel construction activities.
Building and construction materials OES is closest match with this NAICS
code.
238140
Masonry Contractors
Installation and demolition of
formaldehyde based furnishings
and building/construction
materials in residential, public,
and commercial buildings, and
other structures
Building and construction materials OES is closest match with this NAICS
code.
238210
Electrical Contractors and
Other Wiring Installation
Contractors
Installation and demolition of
formaldehyde based furnishings
and building/construction
materials in residential, public,
and commercial buildings, and
other structures
Building and construction materials OES is closest match with this NAICS
code.
238310
Drywall and Insulation
Contractors
Installation and demolition of
formaldehyde based furnishings
and building/construction
materials in residential, public,
and commercial buildings, and
other structures
Building and construction materials OES is closest match with this NAICS
code.
238330
Flooring Contractors
Installation and demolition of
formaldehyde based furnishings
and building/construction
materials in residential, public,
and commercial buildings, and
other structures
Building and construction materials OES is closest match with this NAICS
code.
Page 227 of 313
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NAICS
NAICS Description
Mapped OES
Basis
238350
Finish Carpentry Contractors
Installation and demolition of
formaldehyde based furnishings
and building/construction
materials in residential, public,
and commercial buildings, and
other structures
Building and construction materials OES is closest match with this NAICS
code.
238910
Site Preparation Contractors
Installation and demolition of
formaldehyde based furnishings
and building/construction
materials in residential, public,
and commercial buildings, and
other structures
Building and construction materials OES is closest match with this NAICS
code.
311119
Other Animal Food
Manufacturing
Unknown
NAICS code indicates food manufacturing, which may fall under non-TSCA
uses. A specific use in food manufacturing for a TSCA COU within the
scope of this risk evaluation is not known.
311612
Meat Processed from
Carcasses
Unknown
NAICS code indicates food manufacturing, which may fall under non-TSCA
uses. A specific use in food manufacturing for a TSCA COU within the
scope of this risk evaluation is not known.
311710
Seafood Product Preparation
and Packaging
Unknown
NAICS code indicates food manufacturing, which may fall under non-TSCA
uses. A specific use in food manufacturing for a TSCA COU within the
scope of this risk evaluation is not known.
311811
Retail Bakeries
Unknown
NAICS code indicates food manufacturing, which may fall under non-TSCA
uses. A specific use in food manufacturing for a TSCA COU within the
scope of this risk evaluation is not known.
311812
Commercial Bakeries
Unknown
NAICS code indicates food manufacturing, which may fall under non-TSCA
uses. A specific use in food manufacturing for a TSCA COU within the
scope of this risk evaluation is not known.
311824
Dry Pasta, Dough, and Flour
Mixes Manufacturing from
Purchased Flour
Unknown
NAICS code indicates food manufacturing, which may fall under non-TSCA
uses. A specific use in food manufacturing for a TSCA COU within the
scope of this risk evaluation is not known.
311830
Tortilla Manufacturing
Unknown
NAICS code indicates food manufacturing, which may fall under non-TSCA
uses. A specific use in food manufacturing for a TSCA COU within the
scope of this risk evaluation is not known.
Page 228 of 313
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NAICS
NAICS Description
Mapped OES
Basis
311942
Spice and Extract
Manufacturing
Unknown
NAICS code indicates food manufacturing, which may fall under non-TSCA
uses. A specific use in food manufacturing for a TSCA COU within the
scope of this risk evaluation is not known.
312111
Soft Drink Manufacturing
Unknown
NAICS code indicates food manufacturing, which may fall under non-TSCA
uses. A specific use in food manufacturing for a TSCA COU within the
scope of this risk evaluation is not known.
312112
Bottled Water Manufacturing
Unknown
NAICS code indicates food manufacturing, which may fall under non-TSCA
uses. A specific use in food manufacturing for a TSCA COU within the
scope of this risk evaluation is not known.
312120
Breweries
Unknown
NAICS code indicates food manufacturing, which may fall under non-TSCA
uses. A specific use in food manufacturing for a TSCA COU within the
scope of this risk evaluation is not known.
313110
Fiber, Yarn, and Thread Mills
Textile finishing
Textile finishing OES is closest match with this NAICS code.
313210
Broadwoven Fabric Mills
Textile finishing
Textile finishing OES is closest match with this NAICS code.
313220
Narrow Fabric Mills and
Schiffli Machine Embroidery
Textile finishing
Textile finishing OES is closest match with this NAICS code.
313230
Nonwoven Fabric Mills
Textile finishing
Textile finishing OES is closest match with this NAICS code.
313240
Knit Fabric Mills
Textile finishing
Textile finishing OES is closest match with this NAICS code.
313310
Textile and Fabric Finishing
Mills
Textile finishing
Textile finishing OES is closest match with this NAICS code.
313312
Textile and Fabric Finishing
Mills
Textile finishing
Textile finishing OES is closest match with this NAICS code.
313320
Fabric Coating Mills
Textile finishing
Textile finishing OES is closest match with this NAICS code.
314110
Carpet and Rug Mills
Textile finishing
Textile finishing OES is closest match with this NAICS code.
314120
Curtain and Linen Mills
Textile finishing
Textile finishing OES is closest match with this NAICS code.
314910
Textile Bag and Canvas Mills
Textile finishing
Textile finishing OES is closest match with this NAICS code.
314994
Rope, Cordage, Twine, Tire
Cord, and Tire Fabric Mills
Textile finishing
Textile finishing OES is closest match with this NAICS code.
314999
All Other Miscellaneous
Textile Product Mills
Textile finishing
Textile finishing OES is closest match with this NAICS code.
315210
Cut and Sew Apparel
Contractors
Textile finishing
Textile finishing OES is closest match with this NAICS code.
Page 229 of 313
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NAICS
NAICS Description
Mapped OES
Basis
315220
Men's and Boys' Cut and
Sew Apparel Manufacturing
Textile finishing
Textile finishing OES is closest match with this NAICS code.
315990
Apparel Accessories and
Other Apparel Manufacturing
Textile finishing
Textile finishing OES is closest match with this NAICS code.
316110
Leather and Hide Tanning
and Finishing
Leather tanning
Leather tanning OES is a 1-to-l match with this NAICS code.
321113
Sawmills
Composite wood product
manufacturing
Composite wood product manufacturing closest match NAICS code.
321211
Hardwood Veneer and
Plywood Manufacturing
Composite wood product
manufacturing
Composite wood product manufacturing closest match NAICS code.
321212
Softwood Veneer and
Plywood Manufacturing
Composite wood product
manufacturing
Composite wood product manufacturing closest match NAICS code.
321213
Engineered Wood Member
(except Truss) Manufacturing
Composite wood product
manufacturing
Composite wood product manufacturing closest match NAICS code.
321219
Reconstituted Wood Product
Manufacturing
Composite wood product
manufacturing
Composite wood product manufacturing closest match NAICS code.
321911
Wood Window and Door
Manufacturing
Composite wood product
manufacturing
Composite wood product manufacturing closest match with NAICS code.
321912
Cut Stock, Resawing Lumber,
and Planing
Composite wood product
manufacturing
Composite wood product manufacturing closest match NAICS code.
321918
Other Millwork (including
Flooring)
Composite wood product
manufacturing
Composite wood product manufacturing closest match NAICS code.
321920
Wood Container and Pallet
Manufacturing
Composite wood product
manufacturing
Composite wood product manufacturing closest match NAICS code.
321991
Manufactured Home (Mobile
Home) Manufacturing
Composite wood product
manufacturing
Composite wood product manufacturing closest match NAICS code.
321992
Prefabricated Wood Building
Manufacturing
Composite wood product
manufacturing
Composite wood product manufacturing closest match NAICS code.
321999
All Other Miscellaneous
Wood Product Manufacturing
Composite wood product
manufacturing
Composite wood product manufacturing closest match NAICS code.
Page 230 of 313
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NAICS
NAICS Description
Mapped OES
Basis
322121
Paper (except Newsprint)
Mills
Paper manufacturing
Paper manufacturing is closest match with this NAICS code.
322211
Corrugated and Solid Fiber
Box Manufacturing
Paper manufacturing
Paper manufacturing is closest match with this NAICS code.
322219
Other Paperboard Container
Manufacturing
Paper manufacturing
Paper manufacturing is closest match with this NAICS code.
322220
Paper Bag and Coated and
Treated Paper Manufacturing
Paper manufacturing
Paper manufacturing is closest match with this NAICS code.
322291
Sanitary Paper Product
Manufacturing
Paper manufacturing
Paper manufacturing is closest match with this NAICS code.
322299
All Other Converted Paper
Product Manufacturing
Paper manufacturing
Paper manufacturing is closest match with this NAICS code.
323111
Commercial Printing (except
Screen and Books)
Use of printing ink, toner and
colorant products containing
formaldehyde
Printing OES closest match with this NAICS code.
323113
Commercial Screen Printing
Use of printing ink, toner and
colorant products containing
formaldehyde
Printing OES closest match with this NAICS code.
324122
Asphalt Shingle and Coating
Materials Manufacturing
Processing of formaldehyde
into formulations, mixtures, or
reaction products
Subcategory for this COU lists "Asphalt, paving, roofing, and coating
materials manufacturing," which matches best with this NAICS code.
324199
All Other Petroleum and Coal
Products Manufacturing
Processing of formaldehyde
into formulations, mixtures, or
reaction products
Could be either this OES, or processing as a reactant, as both list
petrochemical manufacturing, a similar industry, under the subcategory for
the corresponding COU. Processing aid is also a potential OES for this
industry based on the COU but PROC - Formulations was chosen as the
most likely OES.
325110
Petrochemical Manufacturing
Processing as a reactant
Could be either this OES, or processing into formulations, as both list
petrochemical manufacturing, under the subcategory for the corresponding
COU. Processing aid is also a potential OES for this industry based on the
COU but PROC - Reactant was chosen as the most likely OES.
Page 231 of 313
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NAICS
NAICS Description
Mapped OES
Basis
325130
Synthetic Dye and Pigment
Manufacturing
Processing as a reactant
Most commonly reported use codes under TRI for this NAICS description, it
is expected that formaldehyde is used as a reactant in the dye/pigment
manufacturing process.
325180
Other Basic Inorganic
Chemical Manufacturing
Processing of formaldehyde
into formulations, mixtures, or
reaction products
Subcategory for this COU lists "all other basic inorganic chemical
manufacturing"
325193
Ethyl Alcohol Manufacturing
Unknown- Combustion sources
Emissions of formaldehyde in the ethanol production process during
fermentation and drying processes would best fit under combustion sources.
325199
All Other Basic Organic
Chemical Manufacturing
Processing as a reactant
Chemical manufacturing matches best with the processing as a reactant
NAICS code.
325211
Plastics Material and Resin
Manufacturing
Processing as a reactant
Formaldehyde is reacted to form FA-based resin materials
325311
Nitrogenous Fertilizer
Manufacturing
Processing as a reactant
Formalin and urea-formaldehyde are used in the manufacture of solid urea
and ureaform, which are used as slow-release nitrogen fertilizer. Therefore,
EPA expects the most likely OES is Processing as a reactant.
325314
Fertilizer (Mixing Only)
Manufacturing
Processing of formaldehyde
into formulations, mixtures, or
reaction products
NAICS description specifies "mixing only," thus Processing into
formulations is most applicable OES.
325320
Pesticide and Other
Agricultural Chemical
Manufacturing
Other - pesticide manufacturing
Could be processing as a reactant or into a formulation per COU table; It is
assigned to formulation COU but seperated as these processes may be non-
TSCA (FIFRA) if formaldehyde is used for making or incorporated into a
pesticide product. Required additional research into the company.
325412
Pharmaceutical Preparation
Manufacturing
Other- pharmaceutical
manufacturing
Processes may be non-TSCA (FDA). Required additional research into the
company.
325510
Paint and Coating
Manufacturing
Processing of formaldehyde
into formulations, mixtures, or
reaction products
NAICS description matches with full COU description for this OES.
325520
Adhesive Manufacturing
Processing as a reactant
Process could be reactant or into formulation per COU table; Based on
NAICS description, matched to this OES.
Page 232 of 313
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NAICS
NAICS Description
Mapped OES
Basis
325611
Soap and Other Detergent
Manufacturing
Processing of formaldehyde
into formulations, mixtures, or
reaction products
Could be either Processing as a reactant or Processing into formulations OES
based on TRI reporting for this NAICS code and based on the NAICS
description. COU table includes soap under PROC - formulation.
325612
Polish and Other Sanitation
Good Manufacturing
Processing of formaldehyde
into formulations, mixtures, or
reaction products
TRI for this NAICS code all indicate formulations OES, consistent with
mapping of similar industry 325611 - Soap and Other Detergent
Manufacturing. Formaldehyde is expected to be a component in
manufacturing of polish and sanitation good manufacturing.
325613
Surface Active Agent
Manufacturing
Processing of formaldehyde
into formulations, mixtures, or
reaction products
TRI reports this NAICS code as both processing as a reactant and PROC -
formulation. COU table indicates surface active agents under PROC -
formulation only.
325620
Toilet Preparation
Manufacturing
Processing of formaldehyde
into formulations, mixtures, or
reaction products
Consistent with mapping of similar industry 325611 - Soap and Other
Detergent Manufacturing.
325910
Printing Ink Manufacturing
Processing of formaldehyde
into formulations, mixtures, or
reaction products
Formaldehyde is known to be present in the finished product of printing ink,
makes PROC - formulation the most likely match for this NAICS code.
Printing OES would be too downstream for this NAICS code.
325991
Custom Compounding of
Purchased Resins
Processing of formaldehyde
into formulations, mixtures, or
reaction products
OES is closest match for this NAICS description, consistent with TRI
reporting for this code. Formaldehyde is known to be present in finished
resins products.
325992
Photographic Film, Paper,
Plate, and Chemical
Manufacturing
Processing of formaldehyde
into formulations, mixtures, or
reaction products
Formaldehyde is used in photographic film processing, OES matches the
chemical manufacturing portion of the NAICS description. EPA expects
photo film processing OES is too downstream for a manufacturing industry.
325998
All Other Miscellaneous
Chemical Product and
Preparation Manufacturing
Processing as a reactant
Broad NAICS description, could also be PROC-formulation OES or a
repackaging OES. Processing as a Reactant was chosen as the best fitting
OES over the alternatives.
326111
Plastics Bag and Pouch
Manufacturing
Plastic product manufacturing
OES matches NAICS description.
326112
Plastics Packaging Film and
Sheet (including Laminated)
Manufacturing
Plastic product manufacturing
OES matches NAICS description.
326113
Unlaminated Plastics Film
and Sheet (except Packaging)
Manufacturing
Plastic product manufacturing
OES matches NAICS description.
Page 233 of 313
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NAICS
NAICS Description
Mapped OES
Basis
326121
Unlaminated Plastics Profile
Shape Manufacturing
Plastic Product Manufacturing
OES matches NAICS description.
326122
Plastics Pipe and Pipe Fitting
Manufacturing
Plastic product manufacturing
Plastic product manufacturing closest OES.
326130
Laminated Plastics Plate,
Sheet (except Packaging), and
Shape Manufacturing
Plastic product manufacturing
OES matches NAICS description.
326191
Plastics Plumbing Fixture
Manufacturing
Plastic product manufacturing
Plastic Product manufacturing closest OES.
326199
All Other Plastics Product
Manufacturing
Plastic product manufacturing
Plastic Product manufacturing closest OES.
326211
Tire Manufacturing (except
Retreading)
Rubber product manufacturing
Rubber product manufacturing closest match with tire manufacturing.
326220
Rubber and Plastics Hoses
and Belting Manufacturing
Rubber product manufacturing
Rubber product manufacturing closest match with tire manufacturing.
326291
Rubber Product
Manufacturing for
Mechanical Use
Rubber product manufacturing
Rubber product manufacturing closest match with tire manufacturing.
326299
All Other Rubber Product
Manufacturing
Rubber product manufacturing
Rubber product manufacturing closest match with tire manufacturing.
327120
Clay Building Material and
Refractories Manufacturing
Other Composite Material
Manufacturing (e.g., roofing,
etc.)
OES matches NAICS description.
327212
Other Pressed and Blown
Glass and Glassware
Manufacturing
Other Composite Material
Manufacturing (e.g., roofing,
etc.)
OES matches NAICS description.
327331
Concrete Block and Brick
Manufacturing
Other Composite Material
Manufacturing (e.g., roofing,
etc.)
OES matches NAICS description.
Page 234 of 313
-------
NAICS
NAICS Description
Mapped OES
Basis
327390
Other Concrete Product
Manufacturing
Other Composite Material
Manufacturing (e.g., roofing,
etc.)
OES matches NAICS description.
327910
Abrasive Product
Manufacturing
Processing of formaldehyde
into formulations, mixtures, or
reaction products
While it could also be composite material manufacturing OES or PROC -
Reactant OES, Other composite material manufacturing was chosen as best
fit.
327991
Cut Stone and Stone Product
Manufacturing
Other composite material
manufacturing (e.g., roofing,
etc.)
OES matches NAICS description.
327993
Mineral Wool Manufacturing
Other composite material
manufacturing (e.g., roofing,
etc.)
This industry is primarily engaged with mineral wool and mineral wool (i.e.,
fiberglass) insulation products. Therefore, EPA expects the most likely OES
is Other composite material manufacturing.
327999
All Other Miscellaneous
Nonmetallic Mineral Product
Manufacturing
Other composite material
manufacturing (e.g., roofing,
etc.)
OES matches NAICS description and matches mapping for similar NAICS
codes.
331110
Iron and Steel Mills and
Ferroalloy Manufacturing
Foundries
Industry consists of processing iron ore, manufacturing iron, manufacturing
steel, and making iron and steel products. Foundries OES is closest match
with this NAICS code.
331210
Iron and Steel Pipe and Tube
Manufacturing from
Purchased Steel
Foundries
Industry consists of manufacturing iron and steel pipes and tubes. Foundries
OES is closest match with this NAICS code.
331221
Rolled Steel Shape
Manufacturing
Foundries
Industry consists of rolling or drawing shapes from purchased steel.
Foundries is the closest match with this NAICS code.
331313
Alumina Refining and
Primary Aluminum
Production
Foundries
Industry includes making aluminum from alumina and casting aluminum
into primary forms. Foundries OES is the closest match with this NAICS
code.
331318
Other Aluminum Rolling,
Drawing, and Extruding
Foundries
Similar industry to 331313, foundries OES is the closest match.
331410
Nonferrous Metal (except
Aluminum) Smelting and
Refining
Foundries
Industry smelts ores into nonferrous metals and refines nonferrous metals.
Foundries OES is the closest match for this NAICS code.
Page 235 of 313
-------
NAICS
NAICS Description
Mapped OES
Basis
331511
Iron Foundries
Foundries
Foundries OES is a match with this NAICS code.
331513
Steel Foundries (except
Investment)
Foundries
Foundries OES is a match with this NAICS code.
331521
Nonferrous Metal Die-
Casting Foundries
Foundries
Foundries OES is a match with this NAICS code.
331522
Nonferrous Metal Die-
Casting Foundries
Foundries
Foundries OES is a match with this NAICS code.
331523
Nonferrous Metal Die-
Casting Foundries
Foundries
Foundries OES is a match with this NAICS code.
331524
Aluminum Foundries (except
Die-Casting)
Foundries
Foundries OES is a match with this NAICS code.
331529
Other Nonferrous Metal
Foundries (except Die-
Casting)
Foundries
Foundries OES is a match with this NAICS code.
332111
Iron and Steel Forging
Foundries
Forging typically involves the shaping of metal into desired shapes.
Formaldehyde should serve the same function in this industry as in
foundries.
332112
Nonferrous Forging
Foundries
Forging typically involves the shaping of metal into desired shapes.
Formaldehyde should serve the same function in this industry as in
foundries.
332114
Custom Roll Forming
Foundries
Industry includes shaping metal products, Foundries OES is closest match
with this NAICS code.
332117
Powder Metallurgy Part
Manufacturing
Foundries
Industry includes molding and pressing metal, Foundries OES is closest
match with this NAICS code.
332119
Metal Crown, Closure, and
Other Metal Stamping (except
Automotive)
Foundries
Industry includes shaping metal products, Foundries OES is closest match
with this NAICS code.
332215
Metal Kitchen Cookware,
Utensil, Cutlery, and Flatware
(except Precious)
Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Industry is comprised of manufacturing metal cookware and utensils. It is
expected that formaldehyde is used in metal coating, therefore the Spray
OES is the best match for this NAICS code.
Page 236 of 313
-------
NAICS
NAICS Description
Mapped OES
Basis
332216
Saw Blade and Handtool
Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Industry is comprised of manufacturing metal tools. It is expected that
formaldehyde is used in metal coating for this process, therefore the spray
OES is the best match for this NAICS code. The Non-spray coating OES
could also be a potential alternative for this NAICS code.
332312
Fabricated Structural Metal
Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Industry is comprised of fabricating structural metal products. Formaldehyde
could be used in an adhesive or coating capacity, both of which fall under
this OES.
332313
Plate Work Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Closest OES match for this NAICS code, formaldehyde likely used as
adhesive or coating.
332321
Metal Window and Door
Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Closest OES match for this NAICS code, formaldehyde likely used as
adhesive or coating.
332322
Sheet Metal Work
Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Closest OES match for this NAICS code, formaldehyde likely used as
adhesive or coating.
332323
Ornamental and Architectural
Metal Work Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Closest OES match for this NAICS code, formaldehyde likely used as
adhesive or coating.
332410
Power Boiler and Heat
Exchanger Manufacturing
Foundries
This NAICS code is unexpected based on TRI/NEI and the COU table. The
establishment for this NAICS code is "Hunter Engineering" located in
Durant, MS which is an automotive servicing company based on online
search of the company. The company website describes the Durant, MS site
as a plant for metal fabrication and finishing Based on this information, the
foundries OES was chosen.
332431
Metal Can Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Formaldehyde is expected to be used in the base coat and varnishes of
aluminum can products. OES matches the NAICS code.
Page 237 of 313
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NAICS
NAICS Description
Mapped OES
Basis
332439
Other Metal Container
Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Spray OES is closest match for NAICS code, similar industry to metal can
manufacturing.
332618
Other Fabricated Wire
Product Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Spray OES is closest match for NAICS code.
332722
Bolt, Nut, Screw, Rivet, and
Washer Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Spray OES is closest match for NAICS code.
332812
Metal Coating, Engraving
(except Jewelry and
Silverware), and Allied
Services to Manufacturers
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Spray OES is closest match for NAICS code, most frequently mapped OES
for this NAICS code in TRI.
332813
Electroplating, Plating,
Polishing, Anodizing, and
Coloring
Processing aid
COU mentions plating as an example which matches the NAICS description.
332911
Industrial Valve
Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Spray OES is most likely for this NAICS code, matches TRI mapping for
facility with this NAICS code.
332912
Fluid Power Valve and Hose
Fitting Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Spray OES most likely for this NAICS code, expected to be similar industry
to 332911 (Industrial Valve Manufacturing).
332913
Plumbing Fixture Fitting and
Trim Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Spray OES most likely for this NAICS code, expected to be similar industry
to 332911 (Industrial Valve Manufacturing).
332919
Other Metal Valve and Pipe
Fitting Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Spray OES most likely for this NAICS code, expected to be similar industry
to 332911 (Industrial Valve Manufacturing).
332992
Small Arms Ammunition
Manufacturing
Use of explosive materials
Formaldehyde is expected to be used as a component in explosive materials
for this OES. Explosive materials is the best OES fit for this NAICS code. It
is also possible that another more upstream OES such as use of coating could
also be an option for this OES.
Page 238 of 313
-------
NAICS
NAICS Description
Mapped OES
Basis
332993
Ammunition (except Small
Arms) Manufacturing
Use of explosive materials
Formaldehyde is expected to be used as a component in explosive materials
for this OES. Explosive materials is the best OES fit for this NAICS code. It
is also possible that another more upstream OES such as use of coating could
also be an option for this OES.
332994
Small Arms, Ordnance, and
Ordnance Accessories
Manufacturing
Use of explosive materials
Formaldehyde is expected to be used as a component in explosive materials
for this OES. Explosive materials is the best OES fit for this NAICS code. It
is also possible that another more upstream OES such as use of coating could
also be an option for this OES.
332995
Small Arms, Ordnance, and
Ordnance Accessories
Manufacturing
Use of explosive materials
Formaldehyde is expected to be used as a component in explosive materials
for this OES. Explosive materials is the best OES fit for this NAICS code. It
is also possible that another more upstream OES such as use of coating could
also be an option for this OES.
332996
Fabricated Pipe and Pipe
Fitting Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Spray OES is most likely for this NAICS code.
332997
All Other Miscellaneous
Fabricated Metal Product
Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Spray OES is most likely for this NAICS code.
332999
All Other Miscellaneous
Fabricated Metal Product
Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Spray OES is most likely for this NAICS code.
333132
Oil and Gas Field Machinery
and Equipment
Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Formaldehyde is expected to be an adhesive or coating in
machinery/equipment manufacturing NAICS codes. Could also be a
processing aid OES, but the spray applications OES was the best fit.
333244
Printing Machinery and
Equipment Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Formaldehyde is expected to be an adhesive or coating in
machinery/equipment manufacturing NAICS codes. Could also be a
processing aid OES, but the spray applications OES was the best fit.
333249
Other Industrial Machinery
Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Formaldehyde is expected to be an adhesive or coating in
machinery/equipment manufacturing NAICS codes. Could also be a
processing aid OES, but the spray applications OES was the best fit.
Page 239 of 313
-------
NAICS
NAICS Description
Mapped OES
Basis
333314
Optical Instrument and Lens
Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Formaldehyde is expected to be an adhesive or coating in
machinery/equipment manufacturing NAICS codes. Could also be a
processing aid OES.
333316
Photographic and
Photocopying Equipment
Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Formaldehyde is expected to be an adhesive or coating in
machinery/equipment manufacturing NAICS codes. The photo processing
OES would likely be too downstream for this NAICS code. Could also be a
processing aid OES, but spray OES selected as the most likely fit.
333413
Industrial and Commercial
Fan and Blower and Air
Purification Equipment
Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Formaldehyde is expected to be an adhesive or coating in
machinery/equipment manufacturing NAICS codes. Could also be a
processing aid OES, but the spray applications OES was the best fit.
333415
Air-Conditioning and Warm
Air Heating Equipment and
Commercial and Industrial
Refrigeration Equipment
Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Formaldehyde is expected to be an adhesive or coating in
machinery/equipment manufacturing NAICS codes. Could also be a
processing aid OES, but the spray applications OES was the best fit.
333511
Industrial Mold
Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Formaldehyde is expected to be an adhesive or coating in
machinery/equipment manufacturing NAICS codes. Could also be a
processing aid OES, but the spray applications OES was the best fit.
333517
Machine Tool Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Formaldehyde is expected to be an adhesive or coating in
machinery/equipment manufacturing NAICS codes. Could also be a
processing aid OES, but the spray applications OES was the best fit.
333613
Mechanical Power
Transmission Equipment
Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Formaldehyde is expected to be an adhesive or coating in
machinery/equipment manufacturing NAICS codes. Could also be a
processing aid OES, but the spray applications OES was the best fit.
333618
Other Engine Equipment
Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Formaldehyde is expected to be an adhesive or coating in
machinery/equipment manufacturing NAICS codes. Could also be a
processing aid OES, but the spray applications OES was the best fit.
Page 240 of 313
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NAICS
NAICS Description
Mapped OES
Basis
333914
Measuring, Dispensing, and
Other Pumping Equipment
Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Formaldehyde is expected to be an adhesive or coating in
machinery/equipment manufacturing NAICS codes. Could also be a
processing aid OES, but the spray applications OES was the best fit.
333992
Welding and Soldering
Equipment Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Formaldehyde is expected to be an adhesive or coating in
machinery/equipment manufacturing NAICS codes. Could also be a
processing aid OES, but the spray applications OES was the best fit.
333993
Packaging Machinery
Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Formaldehyde is expected to be an adhesive or coating in
machinery/equipment manufacturing NAICS codes. Could also be a
processing aid OES. Other use OESs which could be alternatives would be
too downstream for this manufacturing industry. Spray OES is the most
likely match.
333994
Industrial Process Furnace
and Oven Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Formaldehyde is expected to be an adhesive or coating in
machinery/equipment manufacturing NAICS codes. Could also be a
processing aid OES. Other use OESs which could be alternatives would be
too downstream for this manufacturing industry. Spray OES is the most
likely match.
333999
All Other Miscellaneous
General Purpose Machinery
Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Formaldehyde is expected to be an adhesive or coating in
machinery/equipment manufacturing NAICS codes. Could also be a
processing aid OES, but the spray applications OES was the best fit.
334220
Radio and Television
Broadcasting and Wireless
Communications Equipment
Manufacturing
Processing aid
Formaldehyde is expected to be used as an oxidizing/reducing agent or
processing aid in computer and electronic product manufacturing NAICS
codes (334XXX).
334290
Other Communications
Equipment Manufacturing
Processing aid
Formaldehyde is expected to be used as an oxidizing/reducing agent or
processing aid in computer and electronic product manufacturing NAICS
codes (334XXX).
334310
Audio and Video Equipment
Manufacturing
Processing aid
Formaldehyde is expected to be used as an oxidizing/reducing agent or
processing aid in computer and electronic product manufacturing NAICS
codes (334XXX).
334412
Bare Printed Circuit Board
Manufacturing
Processing aid
Processing aid OES closest match for circuit board manufacturing, also
consistent with TRI reporting for this NAICS code.
Page 241 of 313
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NAICS
NAICS Description
Mapped OES
Basis
334416
Capacitor, Resistor, Coil,
Transformer, and Other
Inductor Manufacturing
Processing aid
Formaldehyde is expected to be used as an oxidizing/reducing agent or
processing aid in computer and electronic product manufacturing NAICS
codes (334XXX).
334418
Printed Circuit Assembly
(Electronic Assembly)
Manufacturing
Processing aid
Formaldehyde is expected to be used as an oxidizing/reducing agent or
processing aid in computer and electronic product manufacturing NAICS
codes (334XXX).
334511
Search, Detection,
Navigation, Guidance,
Aeronautical, and Nautical
System and Instrument
Manufacturing
Processing aid
Formaldehyde is expected to be used as an oxidizing/reducing agent or
processing aid in computer and electronic product manufacturing NAICS
codes (334XXX).
334512
Automatic Environmental
Control Manufacturing for
Residential, Commercial, and
Appliance Use
Processing aid
Formaldehyde is expected to be used as an oxidizing/reducing agent or
processing aid in computer and electronic product manufacturing NAICS
codes (334XXX).
334513
Instruments and Related
Products Manufacturing for
Measuring, Displaying, and
Controlling Industrial Process
Variables
Processing aid
Formaldehyde is expected to be used as an oxidizing/reducing agent or
processing aid in computer and electronic product manufacturing NAICS
codes (334XXX).
334514
Totalizing Fluid Meter and
Counting Device
Manufacturing
Processing aid
Formaldehyde is expected to be used as an oxidizing/reducing agent or
processing aid in computer and electronic product manufacturing NAICS
codes (334XXX).
334517
Irradiation Apparatus
Manufacturing
Processing aid
Formaldehyde is expected to be used as an oxidizing/reducing agent or
processing aid in computer and electronic product manufacturing NAICS
codes (334XXX).
334519
Other Measuring and
Controlling Device
Manufacturing
Processing aid
Formaldehyde is expected to be used as an oxidizing/reducing agent or
processing aid in computer and electronic product manufacturing NAICS
codes (334XXX).
335110
Electric Lamp Bulb and Part
Manufacturing
Use of electronic and metal
products
Use of electronic products is the closest match for this OES.
335122
Commercial, Industrial, and
Institutional Electric Lighting
Fixture Manufacturing
Use of electronic and metal
products
Use of electronic products is the closest match for this OES.
Page 242 of 313
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NAICS
NAICS Description
Mapped OES
Basis
335129
Other Lighting Equipment
Manufacturing
Use of electronic and metal
products
Use of electronic products is the closest match for this OES.
335311
Power, Distribution, and
Specialty Transformer
Manufacturing
Use of electronic and metal
products
Use of electronic products is the closest match for this OES.
335312
Motor and Generator
Manufacturing
Use of electronic and metal
products
Use of electronic products is the closest match for this OES.
335313
Switchgear and Switchboard
Apparatus Manufacturing
Use of electronic and metal
products
Use of electronic products is the closest match for this OES.
335999
All Other Miscellaneous
Electrical Equipment and
Component Manufacturing
Use of electronic and metal
products
Use of electronic products is the closest match for this OES.
336111
Automobile Manufacturing
Use of formulations containing
formaldehyde for spray
applications (e.g., spray or roll)
OES closest match for NAICS code.
336112
Light Truck and Utility
Vehicle Manufacturing
Use of formulations containing
formaldehyde for spray
applications (e.g., spray or roll)
OES closest match for NAICS code.
336211
Motor Vehicle Body
Manufacturing
Use of formulations containing
formaldehyde for spray
applications (e.g., spray or roll)
OES closest match for NAICS code.
336212
Truck Trailer Manufacturing
Use of formulations containing
formaldehyde for spray
applications (e.g., spray or roll)
OES closest match for NAICS code.
336213
Motor Home Manufacturing
Installation and demolition of
formaldehyde based furnishings
and building/construction
materials in residential, public,
and commercial buildings, and
other structures
Building and construction materials OES is closest match with this NAICS
code.
Page 243 of 313
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NAICS
NAICS Description
Mapped OES
Basis
336214
Travel Trailer and Camper
Manufacturing
Installation and demolition of
formaldehyde based furnishings
and building/construction
materials in residential, public,
and commercial buildings, and
other structures
Building and construction materials OES is closest match with this NAICS
code.
336310
Motor Vehicle Gasoline
Engine and Engine Parts
Manufacturing
Use of automotive lubricants
OES closest match for NAICS code.
336320
Motor Vehicle Electrical and
Electronic Equipment
Manufacturing
Use of formulations containing
formaldehyde for spray
applications (e.g., spray or roll)
OES closest match for NAICS code.
336340
Motor Vehicle Brake System
Manufacturing
Use of automotive lubricants
OES closest match for NAICS code.
336360
Motor Vehicle Seating and
Interior Trim Manufacturing
Use of formulations containing
formaldehyde for spray
applications (e.g., spray or roll)
OES closest match for NAICS code.
336370
Motor Vehicle Metal
Stamping
Use of formulations containing
formaldehyde for spray
applications (e.g., spray or roll)
OES closest match for NAICS code.
336390
Other Motor Vehicle Parts
Manufacturing
Use of formulations containing
formaldehyde for spray
applications (e.g., spray or roll)
OES closest match for NAICS code.
336399
Other Motor Vehicle Parts
Manufacturing
Use of formulations containing
formaldehyde for spray
applications (e.g., spray or roll)
OES closest match for NAICS code.
336411
Aircraft Manufacturing
Use of formulations containing
formaldehyde for spray
applications (e.g., spray or roll)
Spray OES closest match for NAICS code; however, lubricant is also a
possible match;
Page 244 of 313
-------
NAICS
NAICS Description
Mapped OES
Basis
336412
Aircraft Engine and Engine
Parts Manufacturing
Use of formulations containing
formaldehyde for spray
applications (e.g., spray or roll)
Spray OES closest match for NAICS code; however, lubricant is also a
possible match.
336413
Other Aircraft Parts and
Auxiliary Equipment
Manufacturing
Use of formulations containing
formaldehyde for spray
applications (e.g., spray or roll)
Spray OES closest match for NAICS code; however, lubricant is also a
possible match.
336510
Railroad Rolling Stock
Manufacturing
Use of formulations containing
formaldehyde for spray
applications (e.g., spray or roll)
Spray OES closest match for NAICS code; however, lubricant is also a
possible match.
336611
Ship Building and Repairing
Installation and demolition of
formaldehyde based furnishings
and building/construction
materials in residential, public,
and commercial buildings, and
other structures
Building and construction materials OES is closest match with this NAICS
code.
336612
Boat Building
Installation and demolition of
formaldehyde based furnishings
and building/construction
materials in residential, public,
and commercial buildings, and
other structures
Building and construction materials OES is closest match with this NAICS
code.
336991
Motorcycle, Bicycle, and
Parts Manufacturing
Use of formulations containing
formaldehyde for spray
applications (e.g., spray or roll)
Spray/roll OES is closest match with this NAICS code.
337110
Wood Kitchen Cabinet and
Countertop Manufacturing
Furniture manufacturing
Furniture manufacturing closest match with NAICS code.
337121
Upholstered Household
Furniture Manufacturing
Furniture manufacturing
Furniture manufacturing closest match with NAICS code.
337122
Nonupholstered Wood
Household Furniture
Manufacturing
Furniture manufacturing
Furniture manufacturing closest match with NAICS code.
Page 245 of 313
-------
NAICS
NAICS Description
Mapped OES
Basis
337125
Household Furniture (except
Wood and Metal)
Manufacturing
Furniture manufacturing
Furniture manufacturing closest match with NAICS code.
337127
Institutional Furniture
Manufacturing
Furniture manufacturing
Furniture manufacturing closest match with NAICS code.
337211
Wood Office Furniture
Manufacturing
Furniture manufacturing
Furniture manufacturing closest match with NAICS code.
337214
Office Furniture (except
Wood) Manufacturing
Furniture manufacturing
Furniture manufacturing closest match with NAICS code.
337215
Showcase, Partition,
Shelving, and Locker
Manufacturing
Furniture manufacturing
Furniture manufacturing closest match with NAICS code.
337910
Mattress Manufacturing
Furniture manufacturing
Furniture manufacturing closest match with NAICS code.
337920
Blind and Shade
Manufacturing
Furniture manufacturing
Furniture manufacturing closest match with NAICS code.
339112
Surgical and Medical
Instrument Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Formaldehyde is expected to be an adhesive or coating in
machinery/equipment manufacturing NAICS codes. Could also be a
processing aid OES. Other use OESs that could be alternatives would be too
downstream for this manufacturing industry. Spray OES is the most likely
match.
339113
Surgical Appliance and
Supplies Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Formaldehyde is expected to be an adhesive or coating in
machinery/equipment manufacturing NAICS codes. Could also be a
processing aid OES. Other use OESs that could be alternatives would be too
downstream for this manufacturing industry. Spray OES is the most likely
match.
339114
Dental Equipment and
Supplies Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Formaldehyde is expected to be an adhesive or coating in
machinery/equipment manufacturing NAICS codes. Could also be a
processing aid OES. Other use OESs that could be alternatives would be too
downstream for this manufacturing industry. Spray OES is the most likely
match.
339910
Jewelry and Silverware
Manufacturing
Processing Aid
Formaldehyde is used in electroless plating of copper and silver as a
processing aid.
Page 246 of 313
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NAICS
NAICS Description
Mapped OES
Basis
339920
Sporting and Athletic Goods
Manufacturing
Plastic Product Manufacturing
Assumed plastic sporting/athletic products, industry does not include athletic
apparel manufacturing.
339930
Doll, Toy, and Game
Manufacturing
Plastic product manufacturing
Assumed plastic doll/toy/game products.
339940
Office Supplies (except
Paper) Manufacturing
Plastic product manufacturing
Assumed to be used in plastic office supply products.
339991
Gasket, Packing, and Sealing
Device Manufacturing
Plastic product manufacturing
Assumed plastic gasket/packing/sealing products.
339992
Musical Instrument
Manufacturing
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Formaldehyde is expected to be used in coating or adhesive for musical
instruments. Spray OES fits best for this NAICS code.
339993
Fastener, Button, Needle, and
Pin Manufacturing
Plastic product manufacturing
Assumed plastic fastener, button, needle, and pin products.
339994
Broom, Brush, and Mop
Manufacturing
Plastic product manufacturing
Assumed plastic broom, brush, and mop products.
339999
All Other Miscellaneous
Manufacturing
Plastic product manufacturing
Consistent with mapping for other 33999X NAICS codes.
423210
Furniture Merchant
Wholesalers
Storage and retail of articles
Assumed that wholesalers are not repackaging so Storage/retail OES is most
applicable.
423220
Home Furnishing Merchant
Wholesalers
Storage and retail of articles
Assumed that wholesalers aren not repackaging so Storage/retail OES is
most applicable.
423310
Lumber, Plywood, Millwork,
and Wood Panel Merchant
Wholesalers
Storage and retail of articles
Assumed that wholesalers are not repackaging so Storage/retail OES is most
applicable.
423690
Other Electronic Parts and
Equipment Merchant
Wholesalers
Storage and retail of articles
Assumed that wholesalers are not repackaging so Storage/retail OES is most
applicable.
423730
Warm Air Heating and Air-
Conditioning Equipment and
Supplies Merchant
Wholesalers
Storage and retail of articles
Assumed that wholesalers are not repackaging so Storage/retail OES is most
applicable.
Page 247 of 313
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NAICS
NAICS Description
Mapped OES
Basis
423850
Service Establishment
Equipment and Supplies
Merchant Wholesalers
Storage and retail of articles
Assumed that wholesalers are not repackaging so Storage/retail OES is most
applicable.
423910
Sporting and Recreational
Goods and Supplies Merchant
Wholesalers
Storage and retail of articles
Assumed that wholesalers are not repackaging so Storage/retail OES is most
applicable.
423930
Recyclable Material
Merchant Wholesalers
Recycling
Based on the companies' websites, sites may include recycling processes on
site, and therefore mapping was revised from 'Storage and retail of articles'
to 'Recycling'.
423990
Other Miscellaneous Durable
Goods Merchant Wholesalers
Storage and retail of articles
Assumed that wholesalers are not repackaging so Storage/retail OES is most
applicable.
424120
Stationery and Office
Supplies Merchant
Wholesalers
Storage and retail of articles
Assumed that wholesalers are not repackaging so Storage/retail OES is most
applicable.
424210
Drugs and Druggists'
Sundries Merchant
Wholesalers
Unknown
EPA does not expect products within the scope of this risk evaluation to be
relevant for this NAICS
424310
Piece Goods, Notions, and
Other Dry Goods Merchant
Wholesalers
Unknown
Assumed that wholesalers are not repackaging so Storage/retail OES is most
applicable.
424320
Men's and Boys' Clothing and
Furnishings Merchant
Wholesalers
Storage and retail of articles
Assumed that wholesalers are not repackaging so Storage/retail OES is most
applicable.
424330
Women's, Children's, and
Infants' Clothing and
Accessories Merchant
Wholesalers
Storage and retail of articles
Assumed that wholesalers are not repackaging so Storage/retail OES is most
applicable.
424410
General Line Grocery
Merchant Wholesalers
Unknown
EPA does not expect products within the scope of this risk evaluation to be
relevant for this NAICS
424470
Meat and Meat Product
Merchant Wholesalers
Unknown
EPA does not expect products within the scope of this risk evaluation to be
relevant for this NAICS
Page 248 of 313
-------
NAICS
NAICS Description
Mapped OES
Basis
424690
Other Chemical and Allied
Products Merchant
Wholesalers
Repackaging
This industry is primarily engaged with merchant wholesale distribution of
chemicals and allied products. Therefore, EPA expects the most likely OES
is Repackaging.
424710
Petroleum Bulk Stations and
Terminals
Use of formulations containing
formaldehyde in fuels
NAICS code is closest match for the Fuels OES, industry is comprised of
establishments with bulk liquid storage of petroleum products.
424920
Book, Periodical, and
Newspaper Merchant
Wholesalers
Storage and retail of articles
Assumed that wholesalers are not repackaging so Storage/retail OES is most
applicable.
424930
Flower, Nursery Stock, and
Florists' Supplies Merchant
Wholesalers
Storage and retail of articles
Assumed that wholesalers are nott repackaging so Storage/retail OES is most
applicable.
425120
Wholesale Trade Agents and
Brokers
Unknown
EPA expects emission from multiple types of products in an office setting,
but some of the sites may not be offices. Not attributable to an OES.
441110
New Car Dealers
Use of formulations containing
formaldehyde in automotive
care products
Industry includes repair and maintenance services for Cars, OES is best fit
for that function of the NAICS code. Automotive lubricants is a possible
alternative OES at these sites as well.
442110
Furniture Stores
Storage and retail of articles
Exposure from this NAICS code expected to fall into Storage and retail of
articles assessment category.
442299
All Other Home Furnishings
Stores
Storage and retail of articles
Exposure from this NAICS code expected to fall into Storage and retail of
articles assessment category.
444110
Home Centers
Storage and retail of articles
Exposure from this NAICS code expected to fall into Storage and retail of
articles assessment category.
444130
Hardware Stores
Storage and retail of articles
Exposure from this NAICS code expected to fall into Storage and retail of
articles assessment category.
444190
Other Building Material
Dealers
Storage and retail of articles
Exposure from this NAICS code expected to fall into Storage and retail of
articles assessment category.
445210
Meat Markets
Unknown
EPA is not aware of the use of formaldehyde for this NAICS code.
446120
Cosmetics, Beauty Supplies,
and Perfume Stores
Unknown
Likely non-TSCA uses. No specific use for this NAICS code within the
scope of this risk evaluation is known.
447110
Gasoline Stations with
Convenience Stores
Use of formulations containing
formaldehyde in fuels
OES is closest match, gas station employees could be exposed to
formaldehyde in fuels.
Page 249 of 313
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NAICS
NAICS Description
Mapped OES
Basis
448110
Men's Clothing Stores
Storage and retail of articles
This OES is upstream of the NAICS description; however it is the best fit.
448120
Women's Clothing Stores
Storage and retail of articles
This OES is upstream of the NAICS description; however it is the best fit.
448150
Clothing Accessories Stores
Storage and retail of articles
This OES is upstream of the NAICS description; however it is the best fit.
451110
Sporting Goods Stores
Storage and retail of articles
This OES is upstream of the NAICS description; however it is the best fit.
451130
Sewing, Needlework, and
Piece Goods Stores
Storage and retail of articles
OES is closest match for this NAICS description.
451212
News Dealers and
Newsstands
Unknown
EPA is not aware of the use of formaldehyde for this NAICS code.
452210
Department Stores
Unknown
EPA is not aware of the use of formaldehyde for this NAICS code.
453998
All Other Miscellaneous
Store Retailers (except
Tobacco Stores)
Use of packaging, paper, and
hobby products
Examples listed for this industry includes art supply stores, which would
match this OES. NAICS code is very general and could reasonably be
multiple different OESs.
481111
Scheduled Passenger Air
Transportation
Unknown- Combustion sources
Likely combustion sources for transportation of people.
482111
Line-Haul Railroads
Unknown- Combustion sources
Assumed no repackaging, thus combustion sources is closest fit
484110
General Freight Trucking,
Local
Unknown- Combustion sources
Assumed no repackaging, thus combustion sources is closest fit
485111
Mixed Mode Transit Systems
Unknown- Combustion sources
Likely combustion sources for transportation of people.
487110
Scenic and Sightseeing
Transportation, Land
Unknown- Combustion sources
Likely combustion sources for transportation of people.
488210
Support Activities for Rail
Transportation
Repackaging
Industry includes loading and unloading rail cars, Repackaging OES would
be closest match for that activity.
Page 250 of 313
-------
NAICS
NAICS Description
Mapped OES
Basis
488320
Marine Cargo Handling
Unknown- Combustion sources
Assumed no repackaging, thus combustion sources is closest fit
488490
Other Support Activities for
Road Transportation
Unknown- Combustion sources
Industry includes establishments providing services to road network users.
The combustion sources is the closest match for this NAICS code.
488991
Packing and Crating
Unknown
EPA is not aware of the use of formaldehyde for this NAICS code.
491110
Postal Service
Use of packaging, paper, and
hobby products
Closest OES would be Use of paper for this NAICS description.
492110
Couriers and Express
Delivery Services
Use of packaging, paper, and
hobby products
Closest OES would be Use of paper for this NAICS description.
493110
General Warehousing and
Storage
Repackaging
Could be this or Distribution in commerce OES; assessing repackaging as
conservative.
493190
Other Warehousing and
Storage
Repackaging
Could be this or Distribution in commerce OES; assessing repackaging as
conservative.
511110
Newspaper Publishers
Use of printing ink, toner and
colorant products containing
formaldehyde
OES matches NAICS description.
511120
Periodical Publishers
Use of printing ink, toner and
colorant products containing
formaldehyde
OES matches NAICS description.
522110
Commercial Banking
Unknown
EPA is not aware of the use of formaldehyde for this NAICS code.
524113
Direct Life Insurance Carriers
Unknown
EPA is not aware of the use of formaldehyde for this NAICS code.
531110
Lessors of Residential
Buildings and Dwellings
Unknown
EPA expects emission from multiple types of products in an office setting,
but some of the sites may not be offices. Not attributable to an OES.
531390
Other Activities Related to
Real Estate
Unknown
EPA expects emission from multiple types of products in an office setting,
but some of the sites may not be offices. Not attributable to an OES.
532210
Consumer Electronics and
Appliances Rental
Storage and retail of articles
OES matches NAICS description.
Page 251 of 313
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NAICS
NAICS Description
Mapped OES
Basis
541330
Engineering Services
Unknown
EPA expects emission from multiple types of products in an office setting,
but some of the sites may not be offices. Not attributable to an OES.
541380
Testing Laboratories
General laboratory use
OES matches NAICS description.
541690
Other Scientific and
Technical Consulting
Services
Unknown
EPA expects emission from multiple types of products in an office setting,
but some of the sites may not be offices. Not attributable to an OES.
541713
Research and Development in
Nanotechnology
Use of electronic and metal
products
Closest OES match for this NAICS code, nanotechnology expected to be
applied to electronic products which contain formaldehyde.
541921
Photography Studios, Portrait
Photo processing using
formulations containing
formaldehyde
Closest OES for this NAICS description.
541940
Veterinary Services
General laboratory use
Formaldehyde is expected to be used as a lab chemical in a school setting.
Lab use OES matches best to this NAICS code.
561210
Facilities Support Services
Unknown
EPA expects emission from multiple types of products in an office setting,
but some of the sites may not be offices. Not attributable to an OES.
561311
Employment Placement
Agencies
Unknown
EPA expects emission from multiple types of products in an office setting,
but some of the sites may not be offices. Not attributable to an OES.
561320
Temporary Help Services
Unknown
EPA expects emission from multiple types of products in an office setting,
but some of the sites may not be offices. Not attributable to an OES.
561422
Telemarketing Bureaus and
Other Contact Centers
Unknown
EPA expects emission from multiple types of products in an office setting,
but some of the sites may not be offices. Not attributable to an OES.
561720
Janitorial Services
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Closest fit is spray applications (spray applied cleaning products etc.).
561730
Landscaping Services
Use of fertilizer containing
formaldehyde in outdoors
including lawns
OES matches NAICS description.
Page 252 of 313
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NAICS
NAICS Description
Mapped OES
Basis
562211
Hazardous Waste Treatment
and Disposal
Worker handling of wastes
OES matches NAICS description.
562219
Other Nonhazardous Waste
Treatment and Disposal
Worker handling of wastes
OES matches NAICS description.
562910
Remediation Services
Worker handling of wastes
Remediation processes are being assessed under the Worker handling of
wastes OES for the occupational exposure assessment
562998
All Other Miscellaneous
Waste Management Services
Worker handling of wastes
OES matches NAICS description.
611110
Elementary and Secondary
Schools
Unknown
EPA expects emission from multiple types of products in an office setting,
but some of the sites may not be offices. Not attributable to an OES.
611210
Junior Colleges
General laboratory use
Formaldehyde is expected to be used as a lab chemical in a school setting.
Lab use OES matches best to this NAICS code. It is possible that this
NAICS code would fall under general population and not be within the scope
of the risk evaluation.
611310
Colleges, Universities, and
Professional Schools
General laboratory use
Formaldehyde is expected to be used as a lab chemical in a school setting.
Lab use OES matches best to this NAICS code. It is possible that this
NAICS code would fall under general population and not be within the scope
of the risk evaluation.
611511
Cosmetology and Barber
Schools
Unknown
Likely non-TSCA uses. No specific use for this NAICS code within the
scope of this risk evaluation is known.
621111
Offices of Physicians (except
Mental Health Specialists)
General laboratory use
Formaldehyde is expected to be used as a lab chemical in a medical setting.
Lab use OES matches best to this NAICS code.
621112
Offices of Physicians, Mental
Health Specialists
General laboratory use
Formaldehyde is expected to be used as a lab chemical in a medical setting.
Lab use OES matches best to this NAICS code.
621210
Offices of Dentists
General laboratory use
Formaldehyde is expected to be used as a lab chemical in a medical setting.
Lab use OES matches best to this NAICS code.
621320
Offices of Optometrists
Unknown
EPA is not aware of the use of formaldehyde for this NAICS code
621399
Offices of All Other
Miscellaneous Health
Practitioners
General laboratory use
Formaldehyde is expected to be used as a lab chemical in a medical setting.
Lab use OES matches best to this NAICS code.
Page 253 of 313
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NAICS
NAICS Description
Mapped OES
Basis
621491
HMO Medical Centers
General laboratory use
Formaldehyde is expected to be used as a lab chemical in a medical setting.
Lab use OES matches best to this NAICS code.
621492
Kidney Dialysis Centers
Unknown
Likely non-TSCA uses.
621511
Medical Laboratories
General laboratory use
Formaldehyde is expected to be used as a lab chemical in a medical setting.
Lab use OES matches best to this NAICS code.
621910
Ambulance Services
Unknown
The use of formaldehyde in ambulances is unknown.
621999
All Other Miscellaneous
Ambulatory Health Care
Services
Unknown
The use of formaldehyde in ambulances is unknown.
622110
General Medical and Surgical
Hospitals
General laboratory use
Formaldehyde is expected to be used as a lab chemical in a medical setting.
Lab use OES matches best to this NAICS code.
622310
Specialty (Except Psychiatric
and Substance Abuse)
Hospitals
General laboratory use
Formaldehyde is expected to be used as a lab chemical in a medical setting.
Lab use OES matches best to this NAICS code.
623110
Nursing Care Facilities
(Skilled Nursing Facilities)
Unknown
EPA is not aware of the use of formaldehyde for this NAICS code.
624310
Vocational Rehabilitation
Services
Unknown
EPA is not aware of the use of formaldehyde for this NAICS code.
711110
Theater Companies and
Dinner Theaters
Unknown
EPA is not aware of the use of formaldehyde for this NAICS code.
711310
Promoters of Performing
Arts, Sports, and Similar
Events with Facilities
Unknown
EPA is not aware of the use of formaldehyde for this NAICS code.
713290
Other Gambling Industries
Unknown
EPA is not aware of the use of formaldehyde for this NAICS code.
713990
All Other Amusement and
Recreation Industries
Unknown
EPA is not aware of the use of formaldehyde for this NAICS code.
811111
General Automotive Repair
Use of automotive lubricants
Both COU and OES are applicable to this NAICS description.
811121
Automotive Body, Paint, and
Interior Repair and
Maintenance
Use of Coatings, Paints,
Adhesives, or Sealants (e.g.,
spray or unknown)
Spray application expected for automotive repainting.
Page 254 of 313
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NAICS
NAICS Description
Mapped OES
Basis
811192
Car Washes
Use of formulations containing
formaldehyde in automotive
care products
Formadlehyde is expected to be used as a component in cleaning solutions in
car washes. This would make the closest fit the Automotive care OES.
811310
Commercial and Industrial
Machinery and Equipment
(except Automotive and
Electronic) Repair and
Maintenance
Industrial use of lubricants
Lubricants expected to be used for machinery repair and maintenance.
811420
Reupholstery and Furniture
Repair
Furniture manufacturing
Furniture manufacturing closest match with NAICS code.
811490
Other Personal and
Household Goods Repair and
Maintenance
Furniture manufacturing
Furniture manufacturing closest match with NAICS code.
812111
Barber Shops
Unknown
Likely non-TSCA uses. No close match to OES.
812112
Beauty Salons
Unknown
Likely non-TSCA uses. No close match to OES.
812113
Nail Salons
Unknown
Likely non-TSCA uses. No close match to OES
812210
Funeral Homes and Funeral
Services
Unknown
Likely non-TSCA uses. No close match to OES
812220
Cemeteries and Crematories
Unknown
Likely non-TSCA uses. No close match to OES
812921
Photofinishing Laboratories
(except One-Hour)
Photo processing using
formulations containing
formaldehyde
OES matches NAICS description.
921130
Public Finance Activities
Unknown
EPA expects emission from multiple types of products in an office setting,
but some of the sites may not be offices. Not attributable to an OES.
921190
Other General Government
Support
Unknown
EPA expects emission from multiple types of products in an office setting,
but some of the sites may not be offices. Not attributable to an OES.
922130
Legal Counsel and
Prosecution
Unknown
EPA expects emission from multiple types of products in an office setting,
but some of the sites may not be offices. Not attributable to an OES.
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NAICS
NAICS Description
Mapped OES
Basis
922140
Correctional Institutions
Unknown
EPA expects emission from multiple types of products in an office setting,
but some of the sites may not be offices. Not attributable to an OES.
922160
Fire Protection
Unknown
EPA expects emission from multiple types of products in an office setting,
but some of the sites may not be offices. Not attributable to an OES.
922190
Other Justice, Public Order,
and Safety Activities
Unknown
EPA expects emission from multiple types of products in an office setting,
but some of the sites may not be offices. Not attributable to an OES.
923110
Administration of Education
Programs
Unknown
EPA expects emission from multiple types of products in an office setting,
but some of the sites may not be offices. Not attributable to an OES.
923130
Administration of Human
Resource Programs (except
Education, Public Health, and
Veterans' Affairs Programs)
Unknown
EPA expects emission from multiple types of products in an office setting,
but some of the sites may not be offices. Not attributable to an OES.
923140
Administration of Veterans'
Affairs
Unknown
EPA expects emission from multiple types of products in an office setting,
but some of the sites may not be offices. Not attributable to an OES.
924110
Administration of Air and
Water Resource and Solid
Waste Management Programs
Unknown
EPA expects emission from multiple types of products in an office setting,
but some of the sites may not be offices. Not attributable to an OES.
924120
Administration of
Conservation Programs
Unknown
EPA expects emission from multiple types of products in an office setting,
but some of the sites may not be offices. Not attributable to an OES.
926120
Regulation and
Administration of
Transportation Programs
Unknown
EPA expects emission from multiple types of products in an office setting,
but some of the sites may not be offices. Not attributable to an OES.
926150
Regulation, Licensing, and
Inspection of Miscellaneous
Commercial Sectors
Unknown
EPA expects emission from multiple types of products in an office setting,
but some of the sites may not be offices. Not attributable to an OES.
928110
National Security
Use of explosive materials
This NAICS code encapsulates the entire armed forces. Assumed use of
explosive materials as closest OES match.
Page 256 of 313
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Appendix E ANAYLSIS OF FULL SHIFT CALCULATIONS OF
OSHA CEHD DATA
EPA uses the OSHA chemical exposure health data (CEHD) (OSHA. 2019) which includes a variety of
workplace monitoring data. The general approach to extracting and utilizing OSHA CEHD data is
provided in Section 2.5.1. Of note, OSHA CEHD contains sampling data measured over different
sampling durations. OSHA notes for the database that OSHA compliance officers do not always obtain
an 8-hour or full shift sample. Where the total sample time is less than 8 hours, an assumption needs to
be made about the exposure potential for the remainder of the shift. In cases where EPA has additional
knowledge of the exposure activities or sources, the EPA may assume that the sampled time is intended
to represent a full shift of exposure. In such cases, the sample concentration is assumed to be
representative of the full 8-hour TWA without adjustment. For the formaldehyde risk evaluation, this
assumption was made based on the available supporting information provided with the monitoring data.
The OSHA CEHD does not provide this additional supporting information such as worker activities or
sampling plans. As formaldehyde has both an 8-hour PEL and a 15-minute STEL, EPA assumes that
compliance officers could be sampling for the purposes of comparing specific activities with the OSHA
STEL and not for OSHA PEL purposes. To reduce the level of uncertainties in the exposure estimates,
EPA implemented a cut-off of 5.5 hours for extraction of samples for full shift analysis and assumed that
the unsampled time exposure was zero (e.g., 8-hour TWA = [sample concentration A x sample time A +
sample concentration B x sample time B + 0 x remaining sample time in 8-hour shift/8 hours], where
samples A and B are for the same worker/sample ID). According to the OSHA technical manual, full
shift sampling is defined to at least cover the total time of a work shift minus an hour (OSHA. 2023).
For the purposes of the formaldehyde risk assessment, EPA was interested in assessing 8-hour work
shift exposures. Based on this OSHA definition, the threshold for a full-time 8-hour shift would be 7
hours; however, the Agency also assumed that leniency would be given for activities where sampling
would not occur (e.g., the workers moving in and out of the regulated area, changing out of PPE,
decontaminating, and taking lunch outside of the regulated area). The Agency selected 1.5 hours as the
representation of time spent on these activities leading to a threshold value of 5.5 hours for extraction of
samples for a full shift analysis. This assumption may potentially underestimate exposures if during the
actual unsampled time, exposures are non-zero. EPA investigated the impact of this assumption on
OSHA data that was mapped to in-scope OESs.
Table Apx E-l shows the calculated sample concentrations from the OSHA data considering all
samples with a combined sampling duration above zero. These concentrations only reflect OSHA data
and are not fully representative of the estimate for the exposure scenarios as EPA integrates across
multiple sources for the occupational exposure estimates used. The central tendency and high-end result
are shown for the approach with no 8-hour adjustment, and the approach EPA utilized with an 8-hour
adjustment.
Page 257 of 313
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Table Apx E-l. Analysis of OSHA CEHD
ormaldehyde Data from 1992 to 2021 (All Samples)
Occupational Exposure Scenario
(OES)
Number
of
Samples
Sample Concentrations (ppm)
Central
Tendency
(No
Adjustment)
High End
(No
Adjustment)
Central
Tendency
(8-Hour
Adjustment)
High End
(8-Hour
Adjustment)
Manufacturing of formaldehyde
20
0.125
1.832
0.025
0.308
Processing as a reactant
126
0.189
2.452
0.033
0.811
Use of coatings, paints, adhesives, or
sealants (e.g., spray or unknown)
428
0.071
0.533
0.038
0.377
Rubber product manufacturing
60
0.017
0.296
0.008
0.071
Composite wood product
manufacturing
272
0.112
1.071
0.061
0.570
Other composite material
manufacturing (e.g., roofing, etc.)
133
0.091
0.475
0.044
0.377
Plastic product manufacturing
314
0.094
0.494
0.026
0.292
Paper manufacturing
138
0.061
0.445
0.013
0.344
Processing of formaldehyde into
formulations, mixtures, or reaction
products
159
0.098
2.059
0.018
0.591
Processing aid
78
0.056
0.288
0.017
0.092
Storage and retail of articles
65
0.066
0.475
0.027
0.441
Furniture manufacturing
305
0.105
0.879
0.049
0.594
Repackaging
36
0.089
0.874
0.022
0.515
Foundries
680
0.097
0.658
0.064
0.455
Use of electronic and metal products
44
0.094
0.566
0.050
0.415
Textile finishing
273
0.066
0.566
0.024
0.314
Installation and demolition of
formaldehyde-based furnishings and
building/construction materials in
Residential, public and commercial
buildings, and other structures
58
0.037
0.417
0.009
0.145
Use of automotive lubricants
12
0.029
0.072
0.017
0.025
Use of explosive materials
27
0.065
0.213
0.012
0.045
Use of formulations containing
formaldehyde in automotive care
products
3
0.044
0.278
0.012
0.023
Use of formulations containing
formaldehyde in fuels
10
0.330
2.201
0.089
0.331
Page 258 of 313
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Occupational Exposure Scenario
(OES)
Number
of
Samples
Sample Concentrations (ppm)
Central
Tendency
(No
Adjustment)
High End
(No
Adjustment)
Central
Tendency
(8-Hour
Adjustment)
High End
(8-Hour
Adjustment)
Leather tanning
5
0.230
2.191
0.122
0.194
Use of printing ink, toner, and
colorant products containing
formaldehyde
24
0.051
0.181
0.020
0.098
Photo processing using formulations
containing formaldehyde
14
0.032
0.069
0.007
0.034
Worker handling of wastes
9
0.041
0.112
0.025
0.054
General laboratory use
449
0.148
1.500
0.030
0.465
Use of packaging, paper, and hobby
products
10
0.020
0.215
0.005
0.016
In general, EPA found that when central tendency and high-end TWAs were calculated using all of the
available sampling data, the average percentage difference across all OESs between the two different
approaches for TWA calculation was a 65 percent decrease in the central tendency and a 54 percent
decrease in the high end. Approach one (no adjustment) assumes that the sample time weighted average
is reflective of full shift exposures. With all samples considered, the dataset can include worker
monitoring taken solely for STEL comparison purposes, where EPA expects that compliance officers
target times or tasks during the shift expected to have the highest formaldehyde exposures. These
shorter-term, high exposure events may not be reflective of the entire 8-hour shift. Approach two with
the 8-hour TWA adjustment will comparatively underestimate exposure estimates, with a significant
portion of the work shift assuming no formaldehyde exposure. This discrepancy becomes more
significant for specific scenarios dependent on the number of shorter term samples identified for the
exposure scenario. The scenarios most impacted by the change in the 8-hour TWA calculation approach
included the following:
• Processing as a reactant
• Industrial use of lubricants
• Use of packaging, paper, and hobby products;
• Manufacturing of formaldehyde;
• Use of explosive materials;
• Use of formulations containing formaldehyde in fuels; and
• Use of formulations containing formaldehyde in automotive care products.
The approach to sampling data utilized by the EPA for assessing full shift data from OSHA CEHD
implemented a cutoff threshold of 5.5 hours of sampling time. TableApx E-2 shows the calculated
sample concentrations from the OSHA data for sampling times above the 5.5-hour cutoff. The central
tendency and high-end result are shown for the approach with no 8-hour adjustment, and the approach
EPA utilized with an 8-hour adjustment.
Page 259 of 313
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TableApx E-2. Analysis of OSHA CEHD Formaldehyde Data from 1992 to 2021 (Total Samples
Times >330 Minutes) a
Occupational Exposure Scenario
(OES)
Number
of
Samples
Sample Concentrations (ppm)
Central
Tendency
High-End
Central
Tendency
(8-Hour TWA)
High-End
(8-Hour TWA )
Manufacturing of formaldehyde
6
0.100
1.403
0.079
1.394
Processing as a reactant
54
0.207
1.552
0.186
1.472
Use of formulations containing
formaldehyde for spray applications
(e.g., spray or roll)
252
0.071
0.517
0.067
0.488
Rubber product manufacturing
35
0.009
0.090
0.008
0.083
Composite wood product
manufacturing
155
0.103
0.823
0.099
0.730
Other composite material
manufacturing (e.g., roofing, etc.)
79
0.123
0.472
0.111
0.396
Plastic product manufacturing
155
0.094
0.409
0.081
0.376
Paper manufacturing
72
0.042
0.415
0.037
0.393
Processing of formaldehyde into
formulations, mixtures, or reaction
products
59
0.073
0.720
0.068
0.610
Processing aid
35
0.037
0.109
0.035
0.107
Storage and retail of articles
39
0.136
0.503
0.126
0.475
Furniture manufacturing
156
0.102
0.818
0.098
0.725
Repackaging
7
0.093
0.127
0.086
0.114
Foundries
492
0.098
0.576
0.091
0.526
Use of electronic and metal products
29
0.067
0.510
0.055
0.510
Textile finishing
121
0.076
0.467
0.066
0.411
Installation and demolition of
formaldehyde-based furnishings and
building/construction materials in
residential, public, and commercial
buildings, and other structures
18
0.021
0.159
0.018
0.123
Use of automotive lubricants
6
0.026
0.030
0.021
0.026
Use of explosive materials
7
0.038
0.052
0.035
0.049
Use of formulations containing
formaldehyde in fuels
3
0.279
0.381
0.262
0.352
Use of printing ink, toner, and colorant
products containing formaldehyde
8
0.085
0.164
0.080
0.153
Page 260 of 313
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Occupational Exposure Scenario
(OES)
Number
of
Samples
Sample Concentrations (ppm)
Central
Tendency
High-End
Central
Tendency
(8-Hour TWA)
High-End
(8-Hour TWA )
Photo processing using formulations
containing formaldehyde
4
0.040
0.047
0.033
0.035
Worker handling of wastes
4
0.025
0.048
0.024
0.048
General laboratory use
131
0.098
0.652
0.083
0.627
Use of packaging, paper, and hobby
products
2
0.020
0.027
0.015
0.020
" For this sensitivity analysis EPA applied the cut-off of 330 minutes, EPA calculated time weighted averages, then adjusted
NDs with LOD (based on the highest sample volume). For all samples, time weighted averages below the detection limit
were divided by 2. For the risk evaluation, EPA considered samples below the cut-off that were marked as "eight-hour
calculation used" inOSHA CEHD database as well as followed the approach detailed in Section 2.5.1.
In general, EPA found that when central tendency and high-end TWAs were calculated only using
sampling time data above the 5.5-hour threshold, the average percentage difference across all OESs
between the two different methodologies for TWA calculation was a 9 percent decrease in the central
tendency and a 9 percent decrease in the high end. This is a substantially more marginal discrepancy
between the two calculation methodologies when compared to the discrepancy utilizing all of the
sampling data. This is consistent with EPA expectations for the impact of the assumption of no exposure
during unsampled time, as the samples with durations greater than 5.5 hours will be more representative
of full shift exposure. The difference between the approaches is illustrated further by TableApx E-3
and Table Apx E-4 below which show the central tendency and high-end TWA results for both TWA
calculation approaches as well as both sampling duration methodologies for the processing of
formaldehyde into formulations, mixtures, or reaction products and the paper manufacturing OESs.
Generally, there are about 309 samples between the 5.5-hour cutoff and the half of a typical shift {i.e., 4
hours). EPA believes the 5.5-hour threshold helps reduce the level of uncertainty in the exposure
estimates.
Page 261 of 313
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TableApx E-3. Sampling Concentration Results for Processing of Formaldehyde into
Formulations, Mixtures, or Reaction Products
Total Sampled
Duration
Central Tendency
(ppm)
High-end
(ppm)
8-Hour Adjustment
All
0.098
2.059
No
>330 minutes
0.073
0.720
No
All
0.018
0.591
Yes
>330 minutes
0.068
0.610
Yes
Note: EPA excluded 98 of 157 OSHA CEHD data samples mapped to 'processing of formaldehyde into
formulations, mixtures, or reaction products' for integration into the full shift exposure estimates as the totaled
sample time was <330 minutes. To reduce the levels of uncertainty, the EPA only integrated 59 OSHA CEHD
samples with other data to provide full shift exposure estimates.
Table Apx E-4. Sampling Concentration Results for Paper Manufacturin
K
Total Sampled
Duration
Central Tendency
(ppm)
High-End
(ppm)
8-Hour Adjustment
All
0.061
0.445
No
>330 minutes
0.042
0.415
No
All
0.013
0.344
Yes
>330 minutes
0.037
0.393
Yes
Note: EPA excluded 63 of 130 OSHA CEHD data samples mapped to "processing of formaldehyde into
formulations, mixtures, or reaction products" for integration into the full shift exposure estimates as the totaled
sample time was <330 minutes. To reduce the levels of uncertainty, the EPA only integrated 67 OSHA CEHD
samples with other data to provide full shift exposure estimates.
Three OESs had no OSHA sampling data with sampling durations greater than 5.5 hours: Industrial use
of lubricants, and Use of formulations containing formaldehyde in automotive care products. While this
could potentially be reflective of the type of worker activities with exposure to formaldehyde, it could
also be a result of the low number of OSHA samples for these scenarios in general as industrial use of
lubricants and use formulations containing formaldehyde in automotive care products had just two and
three total samples, respectively. For these scenarios, EPA did not utilize any OSHA data in the
formaldehyde occupational exposure assessment.
Page 262 of 313
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Appendix F CONSIDERATION OF ENGINEERING CONTROLS
AND PERSONAL PROTECTIVE EQUIPMENT
OSHA and NIOSH recommend employers utilize the hierarchy of controls to address hazardous
exposures in the workplace. The hierarchy of controls strategy outlines, in descending order of priority,
the use of elimination, substitution, engineering controls, administrative controls, and lastly PPE. The
hierarchy of controls prioritizes the most effective measures first, which is to eliminate or substitute the
harmful chemical (e.g., use a different process, substitute with a less hazardous material), thereby
preventing or reducing exposure potential. Following elimination and substitution, the hierarchy
recommends engineering controls to isolate employees from the hazard (e.g., source enclosure, local
exhaust ventilation systems), followed by administrative controls (e.g., a rule/policy that directs
employees to not open machine doors when running), or changes in work practices (e.g., maintenance
plan to check equipment to ensure no leaks) to reduce exposure potential. Administrative controls are
policies and procedures instituted and overseen by the employer to limit worker exposures. Under 29
CFR 1910.1000(e), OSHA requires the use of engineering or administrative controls to bring exposures
to the levels permitted under the air contaminants standard whenever feasible. PPE such as respirators
do not replace engineering controls and they are implemented in addition to feasible engineering
controls (29 CFR 1910.134(a)(1)). The PPE (e.g., respirators) could be used as the last means of control,
when the other control measures cannot reduce workplace exposure to the air contaminants standard.
Formaldehyde has an OSHA chemical-specific standard at 29 CFR 1910.1048. The PEL is 0.75 parts
per million (ppm) calculated as an 8-hour time-weighted average (TWA), and the 15-minute STEL is 2
ppm. The OSHA standard also includes but is not limited to requirements for exposure monitoring,
dermal protection, recordkeeping, PPE if other exposure controls are not feasible, and hazard
communication. OSHA has an action level of 0.5 ppm for formaldehyde and if exposures occur at or
above the action level, certain requirements are triggered, such as exposure monitoring and medical
surveillance.
The remainder of this section discusses respiratory protection and glove protection, including protection
factors for various respirators and dermal protection strategies. EPA's estimates of occupational
exposure presented in this document do not assume the use PPE; however, the effect of respiratory and
dermal protection factors on EPA's occupational exposure estimates can be explored in Risk Evaluation
for Formaldehyde - Supplemental Information File: Occupational Risk Calculator.
F.l Respiratory Protection
OSHA's Formaldehyde Standard (29 CFR 1910.1048) requires employers to address occupational
exposures to formaldehyde by implementing engineering and work practice (administrative) controls to
reduce and maintain employee exposures to at or below the PEL TWA and STEL. If feasible
engineering and administrative controls do not reduce exposures to below the PEL TWA or STEL, the
employer must apply these controls to reduce employee exposures to the extent feasible and supplement
them with respirators which satisfy OSHA's standard. Respirator selection provisions are provided in 29
CFR 1910.1048(g) and 1910.134(d) and require that appropriate respirators are selected based on the
respiratory hazard(s) to which the worker will be exposed and workplace and user factors that affect
respirator performance and reliability. Assigned protection factors (APFs) are provided in Table 1 under
29 CFR 1910.134(d)(3)(i)(A) (see also Table Apx F-l below) and refer to the level of respiratory
protection that a respirator or class of respirators could provide to employees when the employer
implements a continuing, effective respiratory protection program. Implementation of a full respiratory
protection program requires employers to provide training, appropriate selection, fit testing, cleaning,
and change-out schedules in order to have confidence in the efficacy of the respiratory protection.
Page 263 of 313
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If respirators are necessary in atmospheres that are not immediately dangerous to life or health, workers
must use NIOSH-certified air-purifying respirators or NIOSH-approved supplied-air respirators with the
appropriate APF. Respirators that meet these criteria may include air-purifying respirators with organic
vapor cartridges. Respirators must meet or exceed the required level of protection listed in Table Apx
F-l. Based on the APF, inhalation exposures may be reduced by a factor of 5 to 10,000 if respirators are
properly worn and fitted.
For atmospheres that are immediately dangerous to life and health, workers must use a full facepiece
pressure demand self-contained breathing apparatus (SCBA) certified by NIOSH for a minimum service
life of 30 minutes or a combination full facepiece pressure demand supplied-air respirator (SAR) with
auxiliary self-contained air supply. Respirators that are provided only for escape from an atmosphere
that is immediately dangerous to life and health must be NIOSH-certified for escape from the
atmosphere in which they will be used.
Table Apx F-l. Assigned Protection Factors for Respirators in OSHA Standard 29 CFR 1910.134
Type of Respirator
Quarter
Mask
Half
Mask
Full
Facepiece
Helmet/
Hood
Loose-Fitting
Facepiece
1. Air-Purifying Respirator
5
10
50
2. Power Air-Purifying Respirator (PAPR)
50
1,000
25/1,000
25
3. Supplied-Air Respirator (SAR) or Airline Respirator
• Demand mode
10
50
• Continuous flow mode
50
1,000
25/1,000
25
• Pressure-demand or other positive-pressure
mode
50
1,000
4. Self-Contained Breathing Apparatus (SCBA)
• Demand mode
10
50
50
• Pressure-demand or other positive-pressure
mode (e.g., open/closed circuit)
10,000
10,000
Source: 29 CFR 1910.134(d)(3)(i)(A).
NIOSH and the BLS conducted a voluntary survey of U.S. employers regarding the use of respiratory
protective devices between August 2001 and January 2002. The survey was sent to a sample of 40,002
establishments designed to represent all private sector establishments. The survey had a 75.5 percent
response rate (NIOSH. 2003b). A voluntary survey may not be representative of all private industry
respirator use patterns as some establishments with low or no respirator use may choose to not respond
to the survey. Therefore, results of the survey may potentially be biased towards higher respirator use.
NIOSH and BLS estimated about 619,400 U.S. establishments used respirators for voluntary or required
purposes (including emergency and non-emergency uses). About 281,800 establishments (45%) were
estimated to have had respirator use for required purposes in the 12 months prior to the survey. The
281,800 U.S. establishments were estimated to represent approximately 4.5 percent of all private
industry establishments in the United States at the time (NIOSH. 2003b).
The survey found that the establishments that required respirator use had the following respirator
program characteristics (NIOSH. 2003b):
• 59 percent provided training to workers on respirator use;
Page 264 of 313
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• 34 percent had a written respiratory protection program;
• 47 percent performed an assessment of the employees' medical fitness to wear respirators; and
• 24 percent included air sampling to determine respirator selection.
Note that the survey report does not provide a result for respirator fit testing or identify if fit testing was
included in one of the other program characteristics.
Of the establishments that had respirator use for a required purpose within the 12 months prior to the
survey, NIOSH and BLS found (NIOSH. 2003b) that
• non-powered air purifying respirators were most common, 94 percent overall and varying from
89 to 100 percent across industry sectors;
• powered air-purifying respirators represented a minority of respirator use, 15 percent overall and
varying from 7 to 22 percent across industry sectors; and
• supplied air respirators represented a minority of respirator use, 17 percent overall and varying
from 4 to 37 percent across industry sectors.
Of the establishments that used non-powered air-purifying respirators for a required purpose within the
12 months prior to the survey, NIOSH and BLS found (NIOSH. 2003b) that a
• large majority used dust masks, 76 percent overall and varying from 56 to 88 percent across
industry sectors;
• varying fraction use half-mask respirators, 52 percent overall and varying from 26 to 66 percent
across industry sectors; and
• varying fraction use full-facepiece respirators, 23 percent overall and varying from 4 to 33
percent across industry sectors.
Table Apx F-2 summarizes the number and percent of all private industry establishments and
employees that used respirators for a required purpose within the 12 months prior to the survey and
includes a breakdown by industry sector (NIOSH. 2003b):
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TableApx F-2. Number and Percent of Establishments and Employees Using Respirators within
12 Months Prior to Survey
Establishments
Employees
Industry
Number
Percent of All
Number
Percent of All
Establishments
Employees
Total Private Industry
281,776
4.5
3,303,414
3.1
Agriculture, Forestry, and Fishing
13,186
9.4
101,778
5.8
Mining
3,493
11.7
53,984
9.9
Construction
64,172
9.6
590,987
8.9
Manufacturing
48,556
12.8
882,475
4.8
Transportation and Public Utilities
10,351
3.7
189,867
2.8
Wholesale Trade
31,238
5.2
182,922
2.6
Retail Trade
16,948
1.3
118,200
0.5
Finance, Insurance, and Real Estate
4,202
0.7
22,911
0.3
Services
89,629
4.0
1,160,289
3.2
F.2 Glove Protection
OSHA's hand protection standard (29 CFR 1910.138) requires employers select and require employees
to use appropriate hand protection when expected to be exposed to hazards such as those from skin
absorption of harmful substances; severe cuts or lacerations; severe abrasions; punctures; chemical
burns; thermal burns; and harmful temperature extremes. Dermal protection selection provisions are
provided in 29 CFR 1910.138(b) and require that appropriate hand protection is selected based on the
performance characteristics of the hand protection relative to the task(s) to be performed, conditions
present, duration of use, and the hazards to which employees will be exposed.
Unlike respiratory protection, OSHA standards do not provide protection factors (PFs) associated with
various hand protection PPE, such as gloves, and data about the frequency of effective glove use—that
is, the proper use of effective gloves—is very limited in industrial settings. Initial literature review
suggests that there is unlikely to be sufficient data to justify a specific probability distribution for
effective glove use for a chemical or industry. Instead, the impact of effective glove use is explored by
considering different percentages of effectiveness.
Gloves only offer barrier protection until the chemical breaks through the glove material. Using a
conceptual model, Cherrie (Cherrie et at.. 2004) proposed a glove workplace protection factor—the ratio
of estimated uptake through the hands without gloves to the estimated uptake though the hands while
wearing gloves: this protection factor is driven by flux, and thus varies with time. The European Centre
for Ecotoxicology and Toxicology of Chemicals Targeted Risk Assessment (ECETOC TRA) model
represents the protection factor of gloves as a fixed, assigned protection factor equal to 5, 10, or 20
(Marquart et at.. 2017) where, similar to the APF for respiratory protection, the inverse of the protection
factor is the fraction of the chemical that penetrates the glove. It should be noted that the described PFs
are not based on experimental values or field investigations of PPE effectiveness, but rather professional
judgements used in the development of the ECETOC TRA Model. EPA did not identify reasonably
available information on PPE usage to corroborate the PFs used in this model.
As indicated in Table Apx F-3, use of PFs above 1 is recommended only for glove materials that have
been tested for permeation against the formaldehyde-containing liquids associated with the COU. EPA
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has not found information that would indicate specific activity training (e.g., procedure for glove
removal and disposal) for tasks where dermal exposure can be expected to occur in a majority of sites in
industrial only OESs, so the PF of 20 would usually not be expected to be achieved.
TableApx F-3. Glove Protection Factors for Different Dermal Protection Strategies from
ECETOC TRA V3
Dermal Protection Characteristics
Affected User
Group
Indicated
Efficiency
(%)
Protection
Factor,
PF
a. Any glove/gauntlet without permeation data and
without employee training
Both industrial and
professional users
0
1
b. Gloves with available permeation data indicating that
the material of construction offers good protection for the
substance
80
5
c. Chemically resistant gloves (i.e., as b above) with
"basic" employee training
90
10
d. Chemically resistant gloves in combination with
specific activity training (e.g., procedure for glove
removal and disposal) for tasks where dermal exposure
can be expected to occur
Industrial users
only
95
20
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Appendix G FACILITY ESTIMATES AND NUMBER OF WORKERS
This appendix presents the number of facilities and worker estimates for each OES. In general, sites
were identified from 2016 and 2020 CDR, 2016 to 2021 TRI, 2015 to 2022 DMR, and 2017 NEI. If
reporting data was not available for a given OES, the number of facilities was determined using U.S.
economic and market data. For further information on the approach and methodology for estimating the
number of facilities, see Section 2.2. Number of workers and ONUs were estimated using Bureau of
Labor Statistics (BLS) and the U.S. Census' Statistics of US Businesses (SUSB) data specific to the
OES (r S HI S_ :0i-; 1 i ensus Bureau. 2015).
G.l Manufacturing of Formaldehyde
In the 2016 CDR, 31 reporters domestically manufactured formaldehyde, one reporter both domestically
manufactured and imported formaldehyde, and the manufacture/import activity for six reporters was
claimed as CBI or withheld (U.S. EPA. 2016). In the 2020 CDR, 37 facilities domestically manufactured
formaldehyde, one facility both domestically manufactured and imported formaldehyde, and the
manufacture/import activity for two facilities was claimed as CBI or withheld ( 020a). Out of
the 37 manufacturing facilities, 21 of the facilities also reported to the 2016 CDR.
The 2019 Nationally Aggregated PV reported in 2020 CDR was 1,000,000,000 to less than
5,000,000,000 lb. Two facilities claimed activities as CBI or withheld ( )20a). EPA did not
identify data on facility operating schedules; therefore, EPA assumes 350 days/yr of operation.
To determine the number of workers, EPA used a combination of CDR and BLS data. In the 2016 and
2020 CDR, data on the number of workers was available for 39 manufacturing sites. There were six
additional manufacturing sites in CDR where data on the number of workers was unavailable. EPA used
the average of the ranges reported in the 2016 and 2020 CDR for 39 sites where data was available, and
the ratio of workers to ONUs from the BLS analysis for the other 6 sites. For the BLS analysis, EPA
used the most commonly reported NAICS code among the manufacturers, which is 325199 - All Other
Basic Organic Chemical Manufacturing. As described in Appendix H, EPA reviewed the occupation
descriptions under this NAICS code and determined that approximately 68 percent of the exposed
personnel are workers and 32 percent are ONUs. CDR data does not differentiate between workers and
ONUs; therefore, EPA assumed the ratio of workers to ONUs would be similar as determined from the
BLS occupation descriptions ( 2023). This resulted in approximately 41 workers per site and
19 ONUs per site. Based on 45 manufacturing sites reported in either 2016 or 2020 CDR, the total
number of workers expected for this OES is 1,827 and the number of ONUs is 860. Totals have been
rounded to two significant figures and may not add exactly due to rounding (see Table Apx G-l).
Page 268 of 313
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Table Apx G-l. >
umber of Workers for Manufacturing
Number
of Sites
Average
Number of
Employees
per Site
Average
Number of
Workers per
Site
Total
Number of
Workers
Average
Number of
ONUs per
Site
Total
Number of
ONUs
Site with a known
number of workers
from CDR
39
60
41
1,595
19
751
Sites with an
unknown number
of workers from
CDR
6
39
232
18
109
Total
45
-
-
1,827
-
860
G.2 Import and/or Repackaging of Formaldehyde
In the 2016 CDR, five reporters imported formaldehyde, and the manufacture/import activity for six
reporters was claimed as CBI ( ). In the 2020 CDR, four facilities imported formaldehyde
and two facilities claimed formaldehyde activities as CBI or withheld ( >20a).
In the 2020 CDR, two manufacturers reported 80 percent of their PV to liquid formaldehyde
repackaging for use as a laboratory chemical in medical diagnostics with a reported PV of 391,614 lb
( 2020a). Both reported less than 10 industrial sites (U.S. EPA. 2020a). EPA assumes a shift
length of 8 hours per day for repackaging facilities, as well as 260 annual operating days. The Agency
estimates an annual throughput for repackaging ranges from 1 to 315,479 kg/site-year (U.S. EPA.
2022a). The 50th and 95th percentiles are 7,000 and 42,000 kg/site-year, respectively (U.S. EPA.
2022a).
Using TRI release data, EPA identified 49 facilities that reported repackaging of formaldehyde under
use information. Within other release databases, EPA identified 188 facilities that may be repackaging
formaldehyde based on their industrial sectors. These sites operated under NAICS code 493190 Other
Warehousing and Storage, 424690 Other Chemical and Allied Product Merchant Wholesaler, 493110
General Warehousing and Storage, 4931 Warehousing and Storage, and 42469 Other Chemical and
Allied Products Merchant Wholesaler.
EPA used data from the BLS and the SUSB specific to the OES to estimate the number of workers and
ON Us per site potentially exposed to formaldehyde during repackaging ( 2016; U.S. Census
Bureau.: ). This approach involved the identification of relevant SOC codes within the BLS data for
the identified NAICS codes. Appendix H includes further details regarding methodology for estimating
the number of workers and ONUs per site. EPA used NAICS codes in Sectors 325 - Chemical
Manufacturing, 327 - Nonmetallic Mineral Product Manufacturing, 424 - Merchant Wholesalers,
Nondurable Goods, 493 - Warehousing and Storage, and 562 - Waste Management and Remediation
Services based on facilities identified as discussed earlier. The full list of NAICS codes assessed for this
OES is listed in Table Apx G-2. The estimated number of workers per site for import/repackaging is
five. Based on an estimated number of sites of 237 for this OES, the total number of workers expected
for this OES is 1,153. The estimated number of ONUs per site for this OES is 2, with a total number of
ONUs of 445.
Page 269 of 313
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Table Apx G-2. Number of Workers for Import and/or Repackaging of Formaldehyde
NAICS Code
Total Number of
Number of
Total Number of
Number of
ONUs/
Site
Total Number
Sites
Workers/ Site
Workers
of ONUs
493190
48
1
68
0.3
13
424690
44
1
56
0.4
20
493110
55
4
202
1
37
4931
8
3
25
1
5
42469
3
1
4
0.4
1
424690
45
1
57
0.4
20
325413
1
43
43
26
26
325193
27
22
581
10
273
325199
2
39
77
18
36
327310
1
22
22
3
3
562211
2
9
18
5
10
424710
1
1
1
0.2
0.2
Total
1,153
445
G.3 Processing as a Reactant
Between 2016 and 2021, 240 facilities reported processing of formaldehyde as a reactant to TRI. As not
all sites may be required to submit to TRI, EPA also considered NEI, DMR, and TRI form A
submissions for specific NAICS codes related to 325 - Chemical Manufacturing. EPA estimates that
potentially 2,513 sites may process formaldehyde as a reactant.
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during processing as a reactant (U.S. BLS. JO I > 1 c. t ^rtsus
Bureau.: ). This approach involved the identification of relevant SOC codes within the BLS data for
the identified NAICS codes. Section 2.4 includes further details regarding methodology for estimating
the number of workers and ONUs per site. EPA assigned NAICS codes in Sectors 31 to 33
(Manufacturing) for this OES based on mapping from TRI reporting data. The full list of NAICS codes
assessed for this OES is listed in Table Apx G-3. The estimated number of workers per site for
processing as a reactant is 25. Based on an estimated number of sites of 2,513 for this OES, the total
number of workers expected for this OES is 62,881. The estimated number of ONUs per site for this
OES is 11, with a total number of ONUs of 27,714.
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Table Apx G-3. Number of Workers for Processing as a Reactant
NAICS Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number
of Workers
Number of
ONUs/Site
Total Number
of ONUs
325998
165
14
2,323
5
767
326130
12
15
184
4
52
325199
191
39
7,374
18
3,472
314994
9
6
56
18
160
325211
241
27
6,621
12
2,909
325110
109
64
6,945
30
3,270
325520
39
18
704
7
264
325613
31
22
675
5
155
325411
30
24
730
15
448
332813
134
8
1,061
2
241
325311
40
17
700
5
204
322299
14
19
272
2
35
325314
21
10
216
3
63
325180
112
25
2,819
12
1,327
321999
72
4
272
1
47
313110
11
16
181
10
115
321219
76
30
2,275
6
432
327993
38
28
1,083
6
216
313310
55
7
376
3
185
322220
84
35
2,959
5
380
311119
136
8
1,081
1
114
336413
33
41
1,357
35
1,144
334413
87
50
4,386
45
3,943
331492
24
14
340
4
107
325130
35
26
900
12
424
325320
29
25
739
7
215
334417
4
41
165
37
148
334412
24
21
506
19
455
326150
24
15
351
4
99
325611
28
19
521
4
119
325194
29
34
992
16
467
325991
25
20
505
7
167
325412
124
44
5,442
27
3,340
327910
19
24
460
5
92
331523
29
19
556
8
224
Page 271 of 313
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NAICS Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number
of Workers
Number of
ONUs/Site
Total Number
of ONUs
324122
46
23
1,036
10
459
321212
38
58
2,213
11
420
339113
16
20
326
6
102
321113
197
6
1,118
1
244
327212
30
18
531
3
87
3251
7
29
200
13
94
325312
12
41
493
12
144
325212
19
25
469
11
206
32519
3
35
104
16
49
32532
3
25
76
7
22
32552
2
18
36
7
14
32513
5
26
129
12
61
32521
1
27
27
12
12
Total
2,513
62,881
27,714
G.4 Composite Wood Product Manufacturing
Between 2016 and 2021, five facilities reported incorporation into an article from within the wood
product manufacturing industry to TRI. As not all sites may be required to submit to TRI, EPA also
considered NEI, DMR, and TRI form A submissions for specific NAICS codes related to 321 - Wood
Product Manufacturing. EPA estimates that potentially 577 sites may process formaldehyde for this
particular OES.
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during processing as a reactant (U.S. BLS. JO I > 1 c. t ^rtsus
Bureau.: ). This approach involved the identification of relevant SOC codes within the BLS data for
the identified NAICS codes. Section 2.4 includes further details regarding methodology for estimating
the number of workers and ONUs per site. EPA assigned NAICS codes in Sectors 31 to 33
(Manufacturing) for this OES based on mapping from TRI reporting data. The full list of NAICS codes
assessed for this OES is listed in Table Apx G-4. The estimated number of workers per site for
processing as a reactant is 25. Based on an estimated number of sites of 2,513 for this OES, the total
number of workers expected for this OES is 62,881. The estimated number of ONUs per site for this
OES is 11, with a total number of ONUs of 27,714.
Page 272 of 313
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Table Apx G-4. Number of Workers for Composite Wood Product Manufacturing
NAICS
Code
Total Number of
Unique Sites
Number of
Workers/ Site
Total Number of
Workers
Number of
ONUs/Site
Total Number
of ONUs
321219
58
30
1736
6
330
321213
9
15
136
3
26
321999
71
4
269
1
47
321211
33
22
710
4
135
321113
196
6
1,112
1
242
321212
37
58
2,154
11
409
321911
30
15
461
3
80
321912
36
9
325
2
56
321920
19
7
124
1
22
321918
48
7
314
1
54
3219
3
8
23
1
4
321114
21
5
113
1
25
321214
1
13
13
2
2
32199
2
6
13
1
2
32121
1
20
20
4
4
32111
1
6
6
1
1
321991
6
27
162
5
28
32192
3
7
20
1
3
32191
2
10
20
2
3
Total
577
13
7,731
3
1,474
G.5 Other Composite Material Manufacturing (e.gRoofing)
EPA assigned NAICS codes in Subsectors 324 - Petroleum and Coal Products Manufacturing, 327 -
Nonmetallic Mineral Product Manufacturing, and 332 - Fabricated Metal Product Manufacturing for
this OES based on mapping from TRI and NEI reporting data. The estimated number of unique sites for
this OES is 608.
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during other composite material manufacturing ( ^
h-i; I i S Census Bureau. 2015). This approach involved the identification of relevant SOC codes
within the BLS data for the identified NAICS codes. Section 2.4 includes further details regarding
methodology for estimating the number of workers and ONUs per site. EPA assigned NAICS codes in
Subsectors 324 - Petroleum and Coal Products Manufacturing, 327 - Nonmetallic Mineral Product
Manufacturing, and 332 - Fabricated Metal Product Manufacturing for this OES based on mapping from
TRI reporting data. The full list of NAICS codes assessed for this OES is listed in TableApx G-5. The
estimated number of workers per site for other composite material manufacturing is 21. Based on an
estimated number of sites of 608 for this OES, the total number of workers expected for this OES is
12,678. The estimated number of ONUs per site for this OES is 4, with a total number of ONUs of 82.
Page 273 of 313
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Table Apx G-5. Number o
Workers for Other Composite Material Manufacturing
NAICS
Code
Total Number
of Unique Sites
Number of
Workers/Site
Total Number of
Workers
Number of
ONUs/Site
Total Number of
ONUs
332618
11
9
97
2
25
324122
46
23
1,036
10
459
327215
17
22
376
4
62
327993
32
28
912
6
182
327910
20
24
484
5
96
327993
32
28
912
6
182
327910
20
24
484
5
96
327310
65
22
1,417
3
218
327215
17
22
376
4
62
32741
3
23
68
5
14
327120
45
24
1,068
4
182
32791
3
24
73
5
14
327993
32
28
912
6
182
327320
152
5
817
1
126
32731
10
22
218
3
34
327992
28
17
478
3
95
327999
26
13
342
3
68
327213
29
87
2,528
14
414
32712
2
24
47
4
8
32732
10
5
54
1
8
327410
15
23
341
5
68
327390
38
11
413
2
64
327331
15
8
125
1
19
32742
13
19
252
4
50
327212
29
18
513
3
84
327211
18
50
900
8
147
327991
8
8
67
2
13
327332
5
11
55
2
9
327420
30
19
582
4
115
327110
13
13
172
2
29
32739
2
11
22
2
3
3274
1
20
20
4
4
32733
1
9
9
1
1
32799
1
12
12
2
2
Total
608
21
12,678
4
82
Page 274 of 313
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G.6 Textile Finishing
EPA did not identify facilities reporting use of formaldehyde for textile finishing in the 2020 CDR.
However, three reporters to the 2016 CDR reported use of formaldehyde in the textiles, apparel, and
leather industry (U.S. EPA. 2016).
Using TRI, NEI, and DMR release data, EPA identified 195 facilities that use formaldehyde for textile
finishing.
Due to CBI claims in the 2016 CDR, the PV is unknown. According to literature, the total number of
garments produced every week may range from 7,000 to 15,000 garments (Echt. 1993; NIOSH. 1983b).
Per the OECD ESD on the Use of Textile Dyes, EPA assumes textile finishing facilities may operate
between 3 1 to 295 days per year (OE( ).
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during textile finishing (I. c. c. -Vl^; 1 c. t -msus Bureau.
2015). This approach involved the identification of relevant SOC codes within the BLS data for the
identified NAICS codes. Section 2.4 includes further details regarding methodology for estimating the
number of workers and ONUs per site. EPA assigned NAICS codes in Subsectors 313 - Textile Mills,
314 - Textile Product Mills, 315 - Apparel Manufacturing, and 316 - Leather and Allied Product
Manufacturing for this OES based on the mapping of OSHA data described in Appendix C. The full list
of NAICS codes assessed for this OES is listed in TableApx G-6. The estimated number of workers per
site for textile finishing is 11. Based on an estimated number of sites of 195 for this OES, the total
number of workers expected for this OES is 2,118. The estimated number of ONUs per site for this OES
is 11, with a total number of ONUs of 2,065.
Table Apx G-6. Number of Workers for Textile Finishing
NAICS
Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number of
Workers
Number of
ONUs/Site
Total Number of
ONUs
313320
17
9
151
4
74
313230
8
19
151
14
114
314999
5
2
9
5
27
313220
3
7
22
6
17
313310
54
7
369
3
182
315110
6
20
118
14
82
31332
6
9
53
4
26
314910
1
2
2
6
6
313110
8
16
131
10
84
315240
5
3
15
14
70
31321
16
14
219
10
165
315280
2
3
5
12
24
315190
1
6
6
4
4
314120
1
3
3
4
4
315990
2
2
4
9
18
Page 275 of 313
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NAICS
Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number of
Workers
Number of
ONUs/Site
Total Number of
ONUs
316210
5
11
57
23
117
315220
2
4
7
17
33
313210
7
14
96
10
72
31411
5
20
98
33
163
31323
9
19
170
14
128
314110
15
20
295
33
488
3133
2
7
14
4
7
314994
5
6
31
18
89
315210
1
1
1
6
6
3132
4
13
51
10
39
31331
3
7
21
3
10
3131
1
16
16
10
10
31499
1
2
2
6
6
Total
195
11
2,118
11
2,065
G.7 Leather Tanning
EPA identified limited information on the number of facilities that may use formaldehyde in leather
tanning. In NEI, EPA identified six sites with NAICS code 31611 - Leather and Hide Tanning and
Finishing.
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during leather tanning (li„S JjjJ * / v v -'hsus Bureau.
2015). This approach involved the identification of relevant SOC codes within the BLS data for the
identified NAICS codes. Section 2.4 includes further details regarding methodology for estimating the
number of workers and ONUs per site. EPA assigned the NAICS code 316110 - Leather and Hide
Tanning and Finishing for this OES based on the mapping of OSHA data described in Appendix C. The
full list of NAICS codes assessed for this OES is listed in Table Apx G-7. The estimated number of
workers per site for leather tanning is 6. Based on an estimated number of sites of 6 for this OES, the
total number of workers expected for this OES is 36. The estimated number of ONUs per site for this
OES is 6, with a total number of ONUs of 33.
Table Apx G-7. Number of Workers for Leather Tanning
NAICS
Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number of
Workers
Number of
ONUs/Site
Total Number of
ONUs
31611
1
6
6
6
6
316110
5
6
30
6
28
Total
6
36
33
Page 276 of 313
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G.8 Rubber Product Manufacturing
EPA did not identify any TRI sub-use information to indicate sites that may incorporate formaldehyde
into an article within industries expected to produce rubber products. EPA considered the relevant
NAICS codes where formaldehyde may be potentially used in rubber product manufacturing. From the
2017 NEI, there are 122 sites under the 4-digit NAICS code 3262 - Rubber Product Manufacturing.
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during rubber product manufacturing (V S HI S 201 •; 1 c.
Census Burt ). This approach involved the identification of relevant SOC codes within the BLS
data for the identified NAICS codes. Section 2.4 includes further details regarding methodology for
estimating the number of workers and ONUs per site. EPA assigned the NAICS code subsector 326 -
Plastics and Rubber Products Manufacturing for this OES based on the mapping of OSHA data
described in Appendix C. The full list of NAICS codes assessed for this OES is listed in TableApx
G-8. The estimated number of workers per site for rubber product manufacturing is 101. Based on an
estimated number of sites of 122 for this OES, the total number of workers expected for this OES is
12,351. The estimated number of ONUs per site for this OES is 16, with a total number of ONUs of
1,984.
Table Apx G-8. Number of Workers for Rubber Product Manufacturing
NAICS
Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number of
Workers
Number of
ONUs/Site
Total Number of
ONUs
326299
48
27
1,317
4
212
326291
12
43
511
7
82
326211
44
225
9,888
36
1,589
32622
2
43
85
7
14
326212
4
10
39
2
6
326220
12
43
511
7
82
Total
122
12,351
1,984
G.9 Paper Manufacturing
EPA identified three sites with TRI sub-use information to indicate sites that may incorporate
formaldehyde into an article within industries expected to produce paper products. In addition, EPA
considered the relevant NAICS codes where formaldehyde may be potentially used in paper product
manufacturing. From the 2017 NEI, there are 462 sites under the 3-digit NAICS code 322 - Paper
Product Manufacturing.
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during paper manufacturing (V S HI S; 1 •; 1 c. t ensus
Bureau.: ). This approach involved the identification of relevant SOC codes within the BLS data for
the identified NAICS codes. Section 2.4 includes further details regarding methodology for estimating
the number of workers and ONUs per site. EPA assigned the NAICS code Subsector 322 - Paper
Manufacturing for this OES based on the mapping of OSHA data described in Appendix C. The full list
of NAICS codes assessed for this OES is listed in TableApx G-9. The estimated number of workers per
site for paper manufacturing is 81. Based on an estimated number of sites of 465 for this OES, the total
number of workers expected for this OES is 37,593. The estimated number of ONUs per site for this
OES is 12, with a total number of ONUs of 5,511.
Page 277 of 313
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Table Apx G-9. Number of Workers for Paper Manufacturing
NAICS
Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number of
Workers
Number of
ONUs/Site
Total Number
of ONUs
322220
84
35
2,959
5
380
322130
55
120
6,626
18
1,013
322110
19
100
1,909
15
292
322121
106
154
16,283
23
2,489
322122
6
91
548
14
84
32211
5
100
502
15
77
32213
11
120
1,325
18
203
32212
3
150
450
23
69
3221
3
133
400
20
61
322291
15
69
1,041
9
134
322211
117
36
4,154
5
533
322299
12
19
234
2
30
322212
15
46
692
6
89
322230
3
24
72
3
9
32222
6
35
211
5
27
322219
5
37
183
5
24
Total
465
37,593
5,511
G. 10 Plastic Product Manufacturing
EPA identified five sites with TRI sub-use information to indicate sites that may incorporate
formaldehyde into an article within industries expected to produce plastic products. EPA considered the
relevant NAICS codes where formaldehyde may be potentially used in plastic product manufacturing.
From the 2017 NEI, there are 469 sites under specific NAICS code within the Subsectors 325 -
Chemical Manufacturing, 326 - Plastics and Rubber Products Manufacturing, and 339 - Miscellaneous
Manufacturing.
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during plastic product manufacturing (V S HI S 201 •; 1 c.
Census Burt ). This approach involved the identification of relevant SOC codes within the BLS
data for the identified NAICS codes. Section 2.4 includes further details regarding methodology for
estimating the number of workers and ONUs per site. EPA assigned the NAICS code Subsectors 325 -
Chemical Manufacturing, 326 - Plastics and Rubber Products Manufacturing, and 339 - Miscellaneous
Manufacturing for this OES based on the mapping of OSHA data described in C.9. The full list of
NAICS codes assessed for this OES is listed in Table Apx G-10. The estimated number of workers per
site for plastic product manufacturing is 17. Based on an estimated number of sites of 474 for this OES,
the total number of workers expected for this OES is 7,917. The estimated number of ONUs per site for
this OES is 5, with a total number of ONUs of 2,202.
Page 278 of 313
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Table Apx G-10. Number of Workers for Plastic Product Manufacturing
NAICS
Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number of
Workers
Number of
ONUs/Site
Total Number of
ONUs
339999
36
5
189
1
43
326121
21
15
325
4
92
326199
100
18
1,811
5
513
32612
4
15
61
4
17
339994
1
20
20
5
5
339920
13
9
115
2
26
326140
50
18
907
5
257
32613
4
15
61
4
17
339991
15
21
316
5
72
326150
22
15
322
4
91
32615
17
15
249
4
70
326111
10
27
272
8
77
326113
49
22
1,080
6
306
3261
8
18
147
5
42
3399
18
7
121
2
28
326191
8
14
110
4
31
326130
12
15
184
4
52
339930
2
5
9
1
2
326112
27
25
687
7
194
339940
4
9
37
2
8
32614
17
18
309
5
87
32619
17
18
304
5
86
339993
5
13
63
3
14
326122
5
15
74
4
21
3391
3
11
34
4
11
326160
2
21
43
6
12
33994
1
9
9
2
2
33993
1
5
5
1
1
325211
2
27
55
12
24
Total
474
7,917
2,202
G. 11 Processing of Formaldehyde into Formulations, Mixtures, or Reaction
Products
Between 2016 and 2021, 189 facilities reported processing of formaldehyde into a formulation to TRI.
As not all sites may be required to submit to TRI, EPA also considered NEI, DMR, and TRI form A
submissions for specific NAICS codes related to NAICS codes in Sectors 31 to 33 (Manufacturing) and
Page 279 of 313
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424 - Merchant Wholesalers, Nondurable Goods. EPA estimates that potentially 1,587 sites may process
formaldehyde into a formulation, mixture, or reaction products.
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during processing into formulations, mixtures, or reaction
products (1, c. Mi S JO i>-; 1, c. t 'ensus Bure ). This approach involved the identification of
relevant SOC codes within the BLS data for the identified NAICS codes. Section 2.4 includes further
details regarding methodology for estimating the number of workers and ONUs per site. EPA assigned
NAICS codes in Sectors 31 to 33 (Manufacturing) and 424 - Merchant Wholesalers, Nondurable Goods
for this OES based on the mapping of OSHA data described in Appendix C.2. The full list of NAICS
codes assessed for this OES is listed in TableApx G-l 1. The estimated number of workers per site for
processing into formulations, mixtures or reaction products is 5. Based on an estimated number of sites
of 1,587 for this OES, the total number of workers expected for this OES is 7,543. The estimated
number of ONUs per site for this OES is 2, with a total number of ONUs of 2,875.
Table Apx G-ll. Number of Workers for Processing of Formaldehyde into Formulations,
Mixture, or Reaction Products
NAICS
Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number of
Workers
Number of
ONUs/Site
Total Number of
ONUs
325180
111
25
2,794
12
1,315
325510
83
14
1,186
5
444
324121
746
6
4,142
2
1,835
325412
122
44
5,354
27
3,286
325910
11
13
143
4
47
327910
21
24
508
5
101
325411
28
24
681
15
418
325314
20
10
206
3
60
324191
23
20
465
9
206
324199
34
17
591
8
262
32518
5
25
126
12
59
32551
10
14
143
5
54
324122
47
23
1,059
10
469
325611
31
19
577
4
132
32591
1
13
13
4
4
325991
25
20
505
7
167
325414
28
54
1,524
33
936
325612
10
17
166
4
38
325920
5
32
158
10
52
325992
10
19
191
6
63
325613
26
22
566
5
130
325620
13
28
360
6
83
32412
4
8
31
3
14
Page 280 of 313
-------
NAICS
Total Number of
Number of
Total Number of
Number of
Total Number of
Code
Unique Sites
Workers/Site
Workers
ONUs/Site
ONUs
32562
4
28
111
6
25
3254
1
41
41
25
25
325413
6
43
256
26
157
32592
1
32
32
10
10
326130
4
15
61
4
17
424690
4
1
5
0.4
2
325211
22
27
604
12
266
325199
21
39
811
18
382
325998
23
14
324
5
107
322220
7
35
247
5
32
325311
10
17
175
5
51
313320
1
9
9
4
4
337110
1
3
3
2
2
322299
2
19
39
2
5
311613
3
9
26
2
5
311119
6
8
48
1
5
313110
1
16
16
10
10
332813
2
8
16
2
4
321219
13
30
389
6
74
333922
1
12
12
6
6
336350
1
67
67
20
20
313230
3
19
57
14
43
322121
3
154
461
23
70
321999
2
4
8
1
1
327993
5
28
142
6
28
332321
1
18
18
5
5
336360
1
74
74
22
22
314994
1
6
6
18
18
325320
25
127
7
37
325130
1
26
26
12
12
334412
1
21
21
19
19
327120
1
24
24
4
4
325520
1
18
18
7
7
321911
1
15
15
3
3
326150
2
15
29
4
8
325194
3
34
103
16
48
Page 281 of 313
-------
NAICS
Total Number of
Number of
Total Number of
Number of
Total Number of
Code
Unique Sites
Workers/Site
Workers
ONUs/Site
ONUs
327215
1
22
22
4
4
311710
1
10
10
2
2
339999
1
5
5
1
1
327212
3
18
53
3
9
339113
1
20
20
6
6
321213
1
15
15
3
3
Total
1,587
7,543
2,875
G. 12 Recycling
As previously mentioned, the recycling of formaldehyde or formaldehyde products was not reported in
the 2020 or 2016 CDR. Using TRI, NEI, and DMR release data, EPA identified 20 facilities that recycle
formaldehyde or formaldehyde products.
EPA did not identify data related to formaldehyde PV or facility throughputs. EPA assumes recycling
facilities operate 5 days/week, 50 weeks/year, or 250 days/year.
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during recycling (I. c. c. .JOh-; I. c. t ^nsus Bureau. 2015).
This approach involved the identification of relevant SOC codes within the BLS data for the identified
NAICS codes. Section 2.4 includes further details regarding methodology for estimating the number of
workers and ONUs per site. EPA assigned the NAICS code 423930 - Recyclable Material Merchant
Wholesalers for this OES based on the mapping of OSHA data described in Appendix C. The full list of
NAICS codes assessed for this OES is listed in Table Apx G-12. The estimated number of workers per
site for recycling is 1. Based on an estimated number of sites of 20 for this OES, the total number of
workers expected for this OES is 25. The estimated number of ONUs per site for this OES is 0.2, with a
total number of ONUs of 3.
Table Apx G-12. Number of Workers for Recyc
ing
NAICS
Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number
of Workers
Number of
ONUs/Site
Total Number
of ONUs
423930
15
1
18
0.2
3
42393
5
1
6
0.2
1
Total
20
25
3
G.13 Storage and Retail Stores
This COU was not reported in the 2020 or 2016 CDR. Using TRI, NEI, and DMR release data, EPA
identified 502 facilities that distribute formaldehyde or formaldehyde products.
EPA did not identify data on facility operating schedules, annual throughputs, or daily throughputs but
assumes that the number of days spent in transit and volumes distributed can vary depending on the
needs of the downstream site receiving formaldehyde. Transit may occur daily or occasionally
depending on downstream user needs. EPA assumes distribution in commerce may occur 365 days/yr.
Page 282 of 313
-------
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during distribution in commerce (:. "• HI < , I v Census
Bureau.: ). This approach involved the identification of relevant SOC codes within the BLS data for
the identified NAICS codes. Section 2.4 includes further details regarding methodology for estimating
the number of workers and ONUs per site. EPA assigned the NAICS code subsectors 423 - Merchant
Wholesalers, Durable Goods, 424 - Merchant Wholesalers, Nondurable Goods, 425 - Wholesale Trade
Agents and Brokers, 444 - Building Material and Garden Equipment and Supplies, 448 - Clothing and
Clothing Accessories Stores, 484 - Truck Transportation, and 532 - Rental and Leasing Services for this
OES based on the mapping of OSHA data described in Appendix C. The full list of NAICS codes
assessed for this OES is listed in TableApx G-13. The estimated number of workers per site for
distribution in commerce is 1. Based on an estimated number of sites of 502 for this OES, the total
number of workers expected for this OES is 590, and the total number of ONUs is 122.
Table Apx G-13. Number of Workers in Storage and Retail Stores
NAICS Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number
of Workers
Number of
ONUs/Site"
Total Number of
ONUs
42331
3
2
5
0.2
1
444190
4
0.3
1
0.04
0.1
423990
1
1
1
0.1
0.1
423310
6
2
9
0.2
1
424210
6
1
6
0.3
2
424930
4
1
3
0.1
1
423120
7
2
15
0.3
2
484220
4
0.4
2
0.03
0.1
42332
2
1
2
0.1
0.3
423320
9
1
8
0.1
1
423110
7
3
19
0.4
3
442110
4
0.1
1
0.1
0.2
423840
3
2
7
0.4
1
423810
8
4
29
0.7
6
424470
2
1
2
0.2
0.3
4481
1
0.01
0.01
0.1
0.1
423210
1
1
1
0.1
0.1
424910
11
1
6
0.1
1
423830
9
2
22
0.5
4
423510
6
1
6
0.4
2
424410
9
2
22
0.4
4
444110
33
4
116
0.4
14
423140
4
1
6
0.2
1
423610
20
1
19
0.4
8
423820
3
3
8
0.5
2
Page 283 of 313
-------
NAICS Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number
of Workers
Number of
ONUs/Site"
Total Number of
ONUs
425120
7
1
7
0.4
3
423860
2
3
6
0.5
1
424610
1
1
1
0.4
0.4
42312
1
2
2
0.3
0.3
532210
2
0.4
1
0.1
0.1
423910
3
1
3
0.1
0.4
451110
4
1
3
0.1
0.4
444130
5
0.3
2
0.04
0.2
423620
6
1
8
0.5
3
423720
7
1
7
0.2
2
444210
8
1
6
0.04
0.3
443142
9
1
7
0.1
1
423450
10
2
24
0.6
6
4442
11
1
10
0.1
1
423490
12
2
21
0.4
5
423130
13
2
25
0.3
3
484210
14
1
9
0.1
1
423430
15
2
37
0.6
9
451120
16
1
18
0.2
2
448190
17
0.01
0.2
0.1
1
442299
18
1
15
0.1
1
424330
19
0.2
4
0.3
5
424990
20
0.3
7
0.1
1
424950
21
0.5
10
0.1
2
448120
22
0.01
0.2
0.1
2
448130
23
0.01
0.3
0.1
2
423420
24
2
45
0.5
11
448150
25
0.01
0.2
0.1
1
Total
502
590
1
a Number of workers and ONUs per site are calculated by dividing the exposed number of workers or occupational
non-users by the number of establishments. The number of workers per site is rounded to the nearest integer. The
number of ONUs per site is shown as 0.2, as it rounds down to zero.
G.14 Furniture Manufacturing
Formaldehyde use for furniture manufacturing was not reported in the 2020 or 2016 CDR. Using TRI,
NEI, and DMR release data, EPA identified 338 facilities that use formaldehyde in furniture
manufacturing.
Page 284 of 313
-------
Facilities typically use coatings for metal and wooden furniture at a rate of 20 to 1,786 L/day and 17.4
L/day, respectively ( >04b). The daily use rate of formaldehyde in furniture coatings is
unknown. Typically, facilities operate for 250 days per year ( 004b).
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during furniture manufacturing (1 c. c. c. t onsus
Bureau.: ). This approach involved the identification of relevant SOC codes within the BLS data for
the identified NAICS codes. Section 2.4 includes further details regarding methodology for estimating
the number of workers and ONUs per site. EPA assigned the NAICS code subsectors 337 - Furniture
and Related Product Manufacturing, 339 - Miscellaneous Manufacturing, and 811 - Repair and
Maintenance for this OES based on the mapping of OSHA data described in Appendix C.9. The full list
of NAICS codes assessed for this OES is listed in TableApx G-14. The estimated number of workers
per site for furniture manufacturing is 6. Based on an estimated number of sites of 338 for this OES, the
total number of workers expected for this OES is 2,180. The estimated number of ONUs per site for this
OES is 4, with a total number of ONUs of 1,340.
Table Apx G-14. Number of Workers for Furniture Manufacturing
NAICS
Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number of
Workers
Number of
ONUs/Site
Total Number of
ONUs
337211
32
9
298
4
128
337110
76
3
257
2
189
339995
6
14
86
3
20
337122
78
3
250
2
184
337125
3
4
12
3
9
337215
19
8
155
4
67
337121
34
13
458
10
336
337920
1
15
15
7
7
33711
26
3
88
2
65
337127
27
9
242
7
178
33721
3
7
22
3
9
337124
3
8
24
6
17
337214
6
22
130
9
56
33712
5
7
35
5
25
337212
11
5
52
2
22
337910
2
24
48
10
21
811420
2
1
2
1
2
3371
1
5
5
4
4
811490
3
1
3
1
2
Total
338
2,180
1,340
Page 285 of 313
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G. 15 Processing Aid
The use of formaldehyde as a processing aid was not reported to the 2020 or 2016 CDR. Based on the
Emission Scenario Document (ESD) on Chemical Vapor Deposition in the Semiconductor Industry, it is
estimated that semiconductor manufacturing sites use precursor chemicals at an annual rate of 50 to
1,000 kg/site-year (OE< ). The ESD on the Semiconductor Industry estimates that
semiconductor facilities will operate 360 days/year (OECD. 2015a). EPA assumes facilities operate 300
days/yr based on the assumption of operations over 7 days/week over some portion of the year since the
chemical may not be processed throughout the entire year.
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during processing aid Q j„ S Jji.S I , I v t 'ensus Bureau.
2015). This approach involved the identification of relevant SOC codes within the BLS data for the
identified NAICS codes. Section 2.4 includes further details regarding methodology for estimating the
number of workers and ONUs per site. EPA assigned the NAICS code sectors 31-33 (Manufacturing)
and subsector 424 - Merchant Wholesalers, Nondurable Goods and 562 - Waste Management and
Remediation Services for this OES based on the mapping of OSHA data described in Appendix C.9. The
full list of NAICS codes assessed for this OES is listed in TableApx G-15. The estimated number of
workers per site for processing aid is 27. Based on an estimated number of sites of 544 for this OES, the
total number of workers expected for this OES is 14,699. The estimated number of ONUs per site for
this OES is 19, with a total number of ONUs of 10,246.
Table Apx G-15. Number of Workers for Processing Aid
NAICS
Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number
of Workers
Number of
ONUs/Site
Total Number of
ONUs
33431
2
10
21
7
14
334511
17
53
907
55
935
334413
87
50
4,386
45
3,943
334416
4
22
87
20
78
332813
139
8
1,100
2
250
33421
1
9
9
9
9
334419
30
20
591
18
532
339910
13
5
64
1
15
334519
6
10
59
10
60
334412
34
21
717
19
644
334417
4
41
165
37
148
334515
1
9
9
10
10
334512
4
9
37
10
38
334514
9
18
166
19
172
334513
12
11
128
11
132
334418
6
28
170
25
153
334220
23
17
397
18
415
334614
8
5
40
5
42
334112
10
42
424
62
616
Page 286 of 313
-------
NAICS
Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number
of Workers
Number of
ONUs/Site
Total Number of
ONUs
334290
4
7
29
8
30
334310
3
10
31
7
21
334210
8
9
71
9
74
334111
15
15
232
23
338
334516
9
15
136
16
140
33422
3
17
52
18
54
334510
6
21
124
21
127
334517
2
22
44
23
45
334118
5
17
83
24
121
334613
1
3
3
3
3
33991
2
5
10
1
2
3344
3
30
89
27
80
325998
3
14
42
5
14
424690
1
1
1
0.4
0.4
322121
6
154
922
23
141
332812
3
7
22
2
5
337214
2
22
43
9
19
339113
2
20
41
6
13
337110
1
3
3
2
2
322299
2
19
39
2
5
311613
2
9
17
2
3
336350
1
67
67
20
20
313110
2
16
33
10
21
325110
1
64
64
30
30
326130
1
15
15
4
4
327993
2
28
57
6
11
313310
1
7
7
3
3
325311
3
17
52
5
15
324110
1
170
170
75
75
331492
1
14
14
4
4
325199
6
39
232
18
109
322130
1
120
120
18
18
336111
1
342
342
45
45
332431
9
31
283
11
98
322110
2
100
201
15
31
325412
2
44
88
27
54
Page 287 of 313
-------
NAICS
Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number
of Workers
Number of
ONUs/Site
Total Number of
ONUs
321219
1
30
30
6
6
311221
2
39
78
9
18
325220
1
47
47
21
21
336112
1
863
863
114
114
321211
1
22
22
4
4
326211
1
225
225
36
36
331315
1
64
64
18
18
331511
1
22
22
9
9
321999
1
4
4
1
1
332439
1
12
12
4
4
331221
1
18
18
5
5
562211
1
9
9
5
5
325411
1
24
24
15
15
424910
1
1
1
0.1
0.1
326150
1
15
15
4
4
311119
1
8
8
1
1
Total
544
14,699
10,246
G.16Use of Formaldehyde for Oilfield Well Production
In the 2020 CDR, five reporters reported the use of formaldehyde in the oil and gas drilling, extraction,
and support activities industry ( )20a). One reporter indicated less than 10 industrial sites,
another reporter indicated 25 to 99 industrial sites, and the other 3 reporters had an unknown number of
industrial sites. In the 2016 CDR, one manufacturer reported use of formaldehyde as a processing aid in
the oil and gas industry in a non-incorporative function ( ). Using TRI, NEI, and DMR
release data, EPA identified 2,875 facilities that potentially use formaldehyde for oilfield well
production based on their NAICS code.
EPA does not possess information regarding the annual operating days for petroleum production. The
ESD on Oil Well Production indicates that facilities typically operate 350 days/year (OECD. 2012). The
ESD on Hydraulic Fracturing indicates that facilities typically operate 350 days/year ( D22d).
The daily petroleum production is generally 5.14 million barrels per day, with a total number of wells as
504,000 in the United States (I ). One reporter in the 2020 CDR reported a PV of 1,240,000
lb ( 020a). FracFocus 3.0 reports 3,022 sites utilize formaldehyde in hydraulic fracturing
fluids across the United States ("GWPC and IPG 22).
EPA used BLS and SUSB data specific to the PES to estimate the number of workers and PNUs per
site potentially exposed to formaldehyde during oilfield well production (U.S. BLS. 2016; U.S. Census
Bureau.: ). This approach involved the identification of relevant SPC codes within the BLS data for
the identified NAICS codes. Section 2.4 includes further details regarding methodology for estimating
the number of workers and PNUs per site. EPA assigned the NAICS code subsectors 211 - Pil and Gas
Page 288 of 313
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Extraction and 213 - Support Activities for Mining for this OES based on the mapping of OSHA data
described in Appendix C.9. The full list of NAICS codes assessed for this OES is listed in Table Apx
G-16. The estimated number of workers per site for oilfield well production is 2. Based on an estimated
number of sites of 2,875 for this OES, the total number of workers expected for this OES is 6,132. The
estimated number of ONUs per site for this OES is 4, with a total number of ONUs of 12,408.
Table Apx G-16. Use of Formaldehyde for Oi
field Well Production
NAICS
Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number of
Workers
Number of
ONUs/Site
Total Number of
ONUs
2111
773
2
1,632
4
3,470
213112
90
3
273
2
197
211130
1,521
2
3,129
4
6,653
211120
418
2
860
4
1828
213111
23
4
102
3
74
21112
28
3
77
4
104
21113
22
3
60
4
82
Total
2,875
6,132
12,408
G. 17 Use of Coatings, Paints, Adhesives, or Sealants (non-spray
applications)
In the 2020 CDR, one reporter reported 30 percent of its PV to use formaldehyde for two-component
glues and adhesives with a maximum concentration of 1 to 30 percent ( )20a). One reporter
to the 2020 CDR reported a PV of 4,860,000 lb ( 20a). Using TRI, NEI, and DMR, EPA
identifies 18 sites potentially using formaldehyde in coatings, paints, adhesives, or sealants in non-spray
applications. As spray applications is expected to have higher exposures, EPA conservatively assesses
many coating-related industries as potentially including spray operations. According to the ESD on the
Use of Adhesives, facilities may operate 200 to 365 days/year with a general throughput of 1,500 to
9,100,000 kg/site-year, depending on the method of application and type of substrate (OECD. 2015b).
In the 2020 CDR, two reporters reported the use of formaldehyde in paints and coatings (U.S. EPA.
2020a). One reporter reported 20 percent of its PV was used for formaldehyde in lacquers, stains,
varnishes, and floor finish with a maximum concentration of 1 to 30 percent ( 20a). The
other reporter reported 3 percent of its PV was used for formaldehyde in solvent-based paint with a
concentration ranging from 30 to 60 percent ( 20a).
Due to CBI in CDR, the exact volume of formaldehyde in paints and coatings is unknown; however, the
PV of one reporter is 3,240,000 lb ( 320a). According to the ESD on Radiation Curable
Coatings, Inks, and Adhesives, facilities typically operate 250 days/year with an annual coating use rate
of 137,000 kg/site-year (O ).
In the 2020 CDR, one reporter reported 20 percent of its PV to the incorporation of formaldehyde into a
formulation, mixture, or reactant product in the transportation equipment manufacturing industry (U.S.
20a). Due to CBI claims in the CDR, the volume of formaldehyde used in the transportation
equipment manufacturing industry is unknown. EPA assumes facilities operate 5 days/week, 50
weeks/year, or 250 days/year.
Page 289 of 313
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EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during use of coatings, paints, adhesives, or sealants (non-spray
applications) ( S. 2016; U.S. Census Bureau. 2015). This approach involved the identification of
relevant SOC codes within the BLS data for the identified NAICS codes. Section 2.4 includes further
details regarding methodology for estimating the number of workers and ONUs per site. EPA assigned
the NAICS code subsector 339 - Miscellaneous Manufacturing for this OES based on the mapping of
OSHA data described in Appendix C.9. The full list of NAICS codes assessed for this OES is listed in
TableApx G-17. The estimated number of workers per site for use of coatings, paints, adhesives, or
sealants (non-spray applications) is nine. Based on an estimated number of sites of 18 for this OES, the
total number of workers expected for this OES is 156. The estimated number of ONUs per site for this
OES is 2, with a total number of ONUs of 42.
Table Apx G-17. Number of Workers for Use of Coatings, Paints, Adhesives, or Sealants
NAICS
Total Number of
Number of
Total Number of
Number of
Total Number of
Code
Unique Sites
Workers/Site
Workers
ONUs/Site
ONUs
339115
3
20
60
6
19
339950
9
5
49
1
11
339992
3
7
22
2
5
33995
1
5
5
1
1
339114
1
10
10
3
3
332196
1
10
10
3
3
Total
18
156
42
G. 18 Industrial Use of Lubricants
Using TRI, NEI, and DMR, EPA identified 10 sites potentially using formaldehyde in lubricants. Due to
a lack of information, EPA did not identify annual or daily site throughputs. EPA assumes facilities use
lubricants 5 days/week, 50 weeks/year, or 250 days/year.
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during the industrial use of lubricants ( 2016; U.S.
Census Bureau. ). This approach involved the identification of relevant SOC codes within the BLS
data for the identified NAICS codes. Section 2.4 includes further details regarding methodology for
estimating the number of workers and ONUs per site. EPA assigned the NAICS codes 811310 —
Commercial and Industrial Machinery and Equipment (except Automotive and Electronic) Repair and
Maintenance and 324110 - Petroleum Refineries for this OES based on the mapping of OSHA data
described in Appendix C.9. The full list of NAICS codes assessed for this OES is listed in TableApx
G-18. The estimated number of workers per site for industrial use of lubricants is 17. Based on an
estimated number of sites of 10 for this OES, the total number of workers expected for this OES is 170.
The estimated number of ONUs per site for this OES is 8, with a total number of ONUs of 75.
Page 290 of 313
-------
Table Apx G-1J
. Number of Workers for Industrial Use of Lubricants
NAICS Code
Total Number
of Unique Sites
Number of
Workers/Site
Total Number
of Workers
Number of
ONUs/Site
Total Number
of ONUs
811310
9
0
0
0
0
324110
1
170
170
75
75
Total
10
170
75
G. 19 Foundries
According to BLS, there are currently 2,61 1 foundries in the United States ( S. 2023). Using
TRI, NEI, and DMR, EPA identified 571 sites with NAICS codes associated with foundries. Large
foundries may produce 75,000 tons per year, while smaller facilities may produce 500 to 1,000 tons per
year (Westbere et ai. 2005). EPA assumes facilities use formaldehyde resins for foundry casting 5
days/week, 50 weeks/year, or 250 days/year.
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during foundry activities ( . 2016; U.S. Census
Bureau.: ). This approach involved the identification of relevant SOC codes within the BLS data for
the identified NAICS codes. Section 2.4 includes further details regarding methodology for estimating
the number of workers and ONUs per site. EPA assigned the NAICS code subsectors 331 - Primary
Metal Manufacturing and 332 - Fabricated Metal Product Manufacturing for this OES based on the
mapping of OSHA data described in Appendix C.9. The full list of NAICS codes assessed for this OES
is listed in Table Apx G-19. The estimated number of workers per site for foundries is 28. Based on an
estimated number of sites of 571 for this OES, the total number of workers expected for this OES is at
least 15,718. The estimated number of ONUs per site for this OES is 9, with a total number of ONUs of
5,162.
Table Apx G-19. Number of Workers for Fount
ries
NAICS
Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number of
Workers
Number of
ONUs/Site
Total Number
of ONUs
331314
33
22
732
6
201
331524
27
11
288
4
116
331318
21
37
785
10
216
33211
3
10
31
4
11
331492
23
14
326
4
102
331511
90
22
2,012
9
810
331315
19
64
1,219
18
336
331110
82
53
4,349
18
1,446
331529
12
8
94
3
38
331523
28
19
537
8
216
332111
28
13
364
5
130
331222
12
23
282
6
69
332119
22
8
179
3
64
331491
21
21
436
7
137
Page 291 of 313
-------
NAICS
Total Number of
Number of
Total Number of
Number of
Total Number
Code
Unique Sites
Workers/Site
Workers
ONUs/Site
of ONUs
331221
20
18
366
5
90
331420
24
32
760
10
239
332117
8
15
121
5
43
33142
2
32
63
10
20
331210
18
39
693
9
170
331513
25
19
468
8
189
33111
7
53
371
18
123
331313
8
37
296
10
81
33121
3
39
116
9
28
331512
6
29
171
12
69
331410
16
19
303
6
95
332112
8
27
216
10
77
33131
2
40
79
11
22
33141
2
19
38
6
12
33151
1
22
22
9
9
Total
571
15,718
5,162
G.20 Installation and Demolition of Formaldehyde-Based Furnishings and
Building/Construction Materials in Residential, Public, and
Commercial Buildings, and Other Structures
In the 2020 CDR, one manufacturer reported 50 percent of its PV to downstream use of formaldehyde in
furniture and furnishings including plastic and leather articles ( 20a). Twelve reporters
reported downstream use of formaldehyde in construction and building materials covering large
surfaces, including wood, metal, cement, stone, and other articles ( 20a). Demolition debris
of wood products from buildings was equal to 36,090 thousand tons in 2015. Total demolition debris
generated in 2015 was 518,242 thousand tons ( 1003). The number and location of sites that
install furniture and furnishings containing formaldehyde are unknown. Due to a lack of information,
EPA does not present daily or annual site throughputs. EPA expects facilities to install furnishings and
construction/building materials 250 days per year.
According to public comment, approximately 8 billion lb of formaldehyde are produced annually in the
United States, with formaldehyde resins for the building products market comprising 60 to 70 percent of
this total (Solenis. 2020). According to the GS on Spray Foam Insulation, 55 million and 365 million lb
of one-component and two-component spray foam are used per year, respectively ( :021a).
The daily use rate of formaldehyde in foam is unknown; however, EPA believes the use of
formaldehyde in spray foam has significantly reduced. The GS indicates that construction crews
typically operate 260 days per year ( ).
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during installation and demolition of formaldehyde-based
furnishings ( v ? l v t onsus Bureau. 2015). This approach involved the identification of
Page 292 of 313
-------
relevant SOC codes within the BLS data for the identified NAICS codes. Section 2.4 includes further
details regarding methodology for estimating the number of workers and ONUs per site. EPA assigned
the NAICS code sector 23 - Construction and the subsector 336 - Transportation Equipment
Manufacturing for this OES based on the mapping of OSHA data described in Appendix C.9. The full
list of NAICS codes assessed for this OES is listed in TableApx G-20. The estimated number of
workers per site for installation and demolition of formaldehyde-based furnishing is 24. Based on an
estimated number of sites of 240 for this OES, the total number of workers expected for this OES is
5,704. The estimated number of ONUs per site for this OES is 6, with a total number of ONUs of 1,500.
Table Apx G-20. Number of Workers for Installation and Demolition of Formaldehyde-Based
Furnishings and Building/Construction Materials in Residential, Public, Commercial Buildings,
and Other Structures
NAICS
Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number of
Workers
Number of
ONUs/Site
Total Number of
ONUs
336611
36
61
2,199
19
671
336612
29
16
458
5
140
237310
39
20
774
4
173
237210
12
1
16
1
11
237130
5
14
70
4
19
238910
8
6
49
1
7
237120
9
35
312
10
86
238210
14
7
101
1
13
238320
7
4
30
0.4
3
236210
11
16
176
8
88
237110
10
6
61
2
17
336213
10
108
1,075
14
142
236220
18
8
142
4
71
236116
6
7
42
2
12
236117
9
5
44
1
12
238220
2
7
13
1
2
238140
1
5
5
1
1
236118
1
2
2
1
1
238990
2
5
10
1
1
236115
3
2
6
1
2
237990
4
13
53
3
14
238160
1
7
7
1
1
238120
1
16
16
2
2
3366
1
36
36
11
11
238110
1
8
8
1
1
Total
240
5,704
1,500
Page 293 of 313
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G.21Use of Formulations Containing Formaldehyde for Water Treatment
Due to CBI claims in CDR, the volume of formaldehyde present in water treatment products is
unknown. According to BLS data, there are a total of 4,228 sites under the NAICS code 221310 - Water
Supply and Irrigation Systems ( i. 2023). The number of sites that use formaldehyde was
estimated using TRI, NEI, and DMR. EPA assigned the NAICS code 221310 for this OES based on
mapping from TRI reporting data. The Agency estimated the number of sites as 388. Water treatment
plants operate on a continuous, year-round schedule; however, formaldehyde may not be used every day
( 4c).
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during water treatment ( v ? l v i -nisus Bureau.
2015). This approach involved the identification of relevant SOC codes within the BLS data for the
identified NAICS codes. Section 2.4 includes further details regarding methodology for estimating the
number of workers and ONUs per site. EPA assigned the NAICS code 221310 - Water Supply and
Irrigation Systems for this OES based on the mapping of OSHA data described in Appendix C.9. The
full list of NAICS codes assessed for this OES is listed in TableApx G-21. The estimated number of
workers per site for water treatment is 2. Based on an estimated number of sites of 388 for this OES, the
total number of workers expected for this OES is 824. The estimated number of ONUs per site for this
OES is 1, with a total number of ONUs of 333.
Table Apx G-21. Number of Workers for Use of Formulations Containing Formaldehyde for
Water Treatment
NAICS
Total Number of
Number of
Total Number of
Number of
Total Number of
Code
Unique Sites
Workers/Site
Workers
ONUs/Site
ONUs
221310
388
2
824
1
333
Total
388
824
333
G.22 Use of Formulations Containing Formaldehyde in Laundry and
Dishwashing Products
The volume of formaldehyde present in industrial or institutional laundry detergents or the number of
sites that use formaldehyde is unknown. U.S. Census Bureau data cited in the ESD on Water Based
Washing Operations at Industrial and Institutional Laundries indicates 4,338 industrial and 95,533
institutional laundries (OE ). According to the ESD, industrial laundry facilities operate over a
range of 20 to 365 days/year while institutional laundry facilities operate over a range of 250 to 365
days/year (OECD.! ).
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during laundry and dishwashing ( 1. 2016; U.S. Census
Bureau.: ). This approach involved the identification of relevant SOC codes within the BLS data for
the identified NAICS codes. Section 2.4 includes further details regarding methodology for estimating
the number of workers and ONUs per site. EPA assigned the NAICS code subsector 812 - Personal and
Laundry Services for this OES based on the mapping of OSHA data described in Appendix C.9. The full
list of NAICS codes assessed for this OES is listed in Table Apx G-22. The estimated number of
workers per site for laundry and dishwashing is 4. Based on an estimated number of sites of 15 for this
OES, the total number of workers expected for this OES is 54. The estimated number of ONUs per site
for this OES is 0.4, with a total number of ONUs of 6.
Page 294 of 313
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TableApx G-22. Number of Workers for Use of Formulations containing Formaldehyde in
Laundry and Dishwashing Products
NAICS
Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number of
Workers
Number of
ONUs/Site
Total Number of
ONUs
812320
15
4
54
0.4
6
Total
15
54
6
G.23Use of Formulations Containing Formaldehyde for Spray Applications
(e.g., Spray or Roll)
Spray application of paints and coatings was not reported in the 2016 or 2020 CDR. In 2004, there were
36,296 automotive refinishing facilities in the United States (oH U j'n,,). Using TRI, NEI, and
DMR, EPA estimates that 4,417 sites potentially use formaldehyde for spray applications. Facilities
generally use 45 to 452 gallons of coating formulation per year, which corresponds to a total daily use
rate of 0.9 gal/site day. Facilities typically operate 250 days per year (OB ).
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during spray applications ( >. 2016; U.S. Census
Bureau.: ). This approach involved the identification of relevant SOC codes within the BLS data for
the identified NAICS codes. Section 2.4 includes further details regarding methodology for estimating
the number of workers and ONUs per site. EPA assigned the NAICS code sectors 332 - Fabricated
Metal Product Manufacturing, 333 - Machinery Manufacturing, 336 - Transportation Equipment
Manufacturing, 339 - Miscellaneous Manufacturing, 561 - Administrative and Support Services, and
811 - Repair and Maintenance for this OES based on the mapping of OSHA data described in Appendix
C.9. The full list of NAICS codes assessed for this OES is listed in TableApx G-23. The estimated
number of workers per site for spray applications is 43. Based on an estimated number of sites of 4,421
for this OES, the total number of workers expected for this OES is 188,017. The estimated number of
ONUs per site for this OES is 17, with a total number of ONUs of 75,249.
Table Apx G-23. Number of Workers for Use of Formulations Containing Formaldehyde for
Spray Applications (e.gSpray or Roll)
NAICS Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number of
Workers
Number of
ONUs/Site
Total Number
of ONUs
332431
69
31
2,171
11
749
336111
41
342
14,007
45
1,851
336112
9
863
7,763
114
1,026
336350
12
67
801
20
237
332420
8
16
124
5
43
336390
93
45
4,187
13
1,239
333922
3
12
35
6
18
332312
31
11
356
3
95
332321
15
18
263
5
70
332999
63
6
353
2
136
336413
32
41
1,316
35
1,110
Page 295 of 313
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NAICS Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number of
Workers
Number of
ONUs/Site
Total Number
of ONUs
339112
22
34
752
11
236
33911
4
11
45
4
14
336212
18
45
815
6
108
333618
35
37
1,300
20
705
811121
225
3
746
0.3
74
332812
186
7
1,343
2
306
336370
11
60
658
18
195
336211
43
33
1,426
4
189
333111
25
16
402
7
187
336510
11
35
385
15
162
339113
15
20
305
6
96
332216
11
7
77
3
30
333991
2
14
28
7
14
333249
17
7
122
6
95
333994
5
9
43
4
21
336992
9
45
405
11
103
333996
2
18
35
9
18
332996
1
12
12
5
5
333612
2
18
37
10
20
333611
3
40
119
21
64
33641
4
75
302
64
255
333318
5
15
75
7
35
332311
6
14
85
4
23
332721
7
4
27
2
14
33636
8
74
592
22
175
336411
9
184
1,653
155
1,394
332991
10
39
390
15
150
332618
11
9
97
2
25
333131
12
14
168
6
78
332811
13
10
128
2
29
332919
14
18
254
7
98
333923
15
16
247
8
124
336320
16
43
686
13
203
333120
17
23
399
11
186
333912
18
19
347
10
174
332710
19
2
33
1
17
Page 296 of 313
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NAICS Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number of
Workers
Number of
ONUs/Site
Total Number
of ONUs
333999
20
9
175
4
88
333914
21
17
366
9
183
333515
22
4
97
3
73
333924
23
19
446
10
224
333242
24
23
540
18
421
333413
25
21
521
6
141
332322
26
9
244
2
65
333519
27
7
176
5
132
333995
28
20
557
10
280
333613
29
18
536
10
290
333921
30
11
342
6
172
336991
31
12
383
3
97
336999
32
15
483
4
123
332911
34
22
745
8
287
333415
34
43
1,472
12
397
33312
35
23
822
11
382
332722
36
6
221
3
116
332323
37
5
201
1
53
336360
38
74
2,812
22
832
332215
39
8
304
3
118
33242
40
16
621
5
214
332510
41
12
489
4
146
332313
42
10
420
3
112
333414
43
17
720
5
194
333243
44
9
382
7
298
333514
45
4
160
3
120
333244
46
6
273
5
213
332913
47
19
872
7
336
336214
48
40
1,896
5
251
336330
49
67
3,272
20
969
333314
50
13
655
6
306
33635
51
67
3,404
20
1,008
333517
52
5
261
4
196
332912
53
28
1468
11
566
33361
54
29
1578
16
855
332613
55
13
739
3
192
Page 297 of 313
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NAICS Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number of
Workers
Number of
ONUs/Site
Total Number
of ONUs
333112
56
29
1,635
14
760
333997
57
10
585
5
294
333132
58
21
1,243
10
577
333241
59
9
503
7
392
336120
60
320
19,181
42
2,534
336419
61
30
1,819
25
1,534
336415
62
132
8,162
111
6,884
33633
63
67
4,207
20
1,245
33324
64
8
530
6
413
33251
65
12
775
4
232
33639
66
45
2,971
13
879
333992
67
11
732
5
367
33651
68
35
2,381
15
999
33637
69
60
4,129
18
1,222
33612
70
320
22,377
42
2,957
333316
71
7
514
3
240
336414
72
372
26,812
314
22,613
333511
73
4
315
3
236
33221
74
7
531
3
207
3335
75
4
322
3
241
33299
76
9
694
4
268
3364
77
75
5,813
64
4,903
33331
78
14
1,072
6
501
3339
79
13
1,009
6
507
3329
80
12
935
5
360
561720
81
1
52
0.1
8
3363
82
51
4,147
15
1,228
Total
4,421
188,017
75,249
G.24Use of Electronic and Metal Products
The volume of formaldehyde present in electronic and metal products is unknown. Using TRI, NEI, and
DMR, EPA estimates 134 sites potentially using formaldehyde for this OES. Due to a lack of
information, EPA does not present annual or daily site throughputs. The Agency assumes facilities use
electronic and metal products 250 days/year, although it is uncertain that formaldehyde is used every
day.
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during use of electronic and metal products (IJ..S HI S. 2016;
Page 298 of 313
-------
lis C 'casus Bureau. 2015). This approach involved the identification of relevant SOC codes within the
BLS data for the identified NAICS codes. Section 2.4 includes further details regarding methodology for
estimating the number of workers and ONUs per site. EPA assigned the NAICS code subsector 335 -
Electrical Equipment, Appliance, and Component Manufacturing for this OES based on the mapping of
OSHA data described in Appendix C.9. The full list of NAICS codes assessed for this OES is listed in
Table Apx G-24. The estimated number of workers per site for use of electronic and metal products is
41. Based on an estimated number of sites of 126 for this OES, the total number of workers expected for
this OES is 5,225. The estimated number of ONUs per site for this OES is 14, with a total number of
ONUs of 1,708.
Table Apx G-24. Number of Workers for Use of Electronics and IV
etal Products
NAICS Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number of
Workers
Number of
ONUs/Site
Total Number
of ONUs
335312
26
34
889
15
387
335999
6
13
79
5
28
335991
17
21
365
8
132
335931
5
25
123
9
44
335313
11
32
355
14
154
335912
2
32
65
12
23
335311
6
39
231
17
100
335121
5
10
50
3
14
335911
16
54
867
20
313
335932
5
35
174
13
63
335314
4
19
77
8
33
335929
4
30
119
11
43
33521
1
53
53
10
10
335210
4
53
213
10
41
335129
1
21
21
6
6
335921
1
20
20
7
7
335220
7
180
1,259
35
245
335122
3
19
58
5
16
33522
1
180
180
35
35
33531
1
28
28
12
12
Total
126
5,225
1,708
G.25Use of Formulations Containing Formaldehyde in Fuels
Using specific codes within the NAICS code subsectors 221 - Utilities, 324 - Petroleum and Coal
Products Manufacturing, 325 - Chemical Manufacturing, 327 -Nonmetallic Mineral Product
Manufacturing, 336 - Transportation Equipment Manufacturing, 424 - Merchant Wholesalers,
Nondurable Goods, and 447 - Gasoline Stations, EPA estimates number of sites of 139 for this OES.
Page 299 of 313
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EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during use in fuels ( S. 2016; U.S. Census Bureau.
2015). This approach involved the identification of relevant SOC codes within the BLS data for the
identified NAICS codes. Section 2.4 includes further details regarding methodology for estimating the
number of workers and ONUs per site. EPA assigned the NAICS code subsectors 221 - Utilities, 324 -
Petroleum and Coal Products Manufacturing, 325 - Chemical Manufacturing, 327 - Nonmetallic
Mineral Product Manufacturing, 336 - Transportation Equipment Manufacturing, 424 - Merchant
Wholesalers, Nondurable Goods, and 447 - Gasoline Stations for this OES based on based on the
mapping of OSHA data described in Appendix C.9. The full list of NAICS codes assessed for this OES
is listed in TableApx G-25. The estimated number of workers per site for use in fuels is 11. Based on
an estimated number of sites of 139 for this OES, the total number of workers expected for this OES is
1,551. The estimated number of ONUs per site for this OES is 2, with a total number of ONUs of 347.
Table Apx G-25. Number of Workers for Use of Formulations Containing Formaldehyde in Fuels
NAICS
Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number of
Workers
Number of
ON Us/Site
Total Number of
ONUs
424710
106
1
152
0.2
18
447110
20
0.2
4
0.01
0.3
221112
2
6
11
8
15
324110
2
170
340
75
151
327992
2
17
34
3
7
325193
1
22
22
10
10
327310
4
22
87
3
13
325199
1
39
39
18
18
336112
1
863
863
114
114
Total
139
11
1,551
2
347
G.26Use of Automotive Lubricants
The ESD on Automotive Lubricants indicates there are 93,270 automotive service sites based on 2012
U.S. Census data (OECD. 2020). The volume of formaldehyde in automotive lubricants is unknown.
Using TRI, NEI, and DMR, EPA estimates a number of sites of 72. Facilities typically use automotive
lubricants 253 days per year with an average annual use rate of 40,000 kg lubricant/site-yr (
2020).
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during use of automotive lubricants (115 JiLS. 1
Census Bureau. ). This approach involved the identification of relevant SOC codes within the BLS
data for the identified NAICS codes. Section 2.4 includes further details regarding methodology for
estimating the number of workers and ONUs per site. EPA assigned the NAICS code subsector 336 -
Transportation Equipment Manufacturing and NAICS codes 332410 - Power Boiler and Heat
Exchanger Manufacturing and 811111 - General Automotive Repair for this OES based on the mapping
of OSHA data described in Appendix C.9. The full list of NAICS codes assessed for this OES is listed in
Table Apx G-26. The estimated number of workers per site for use of automotive lubricants is 31.
Based on an estimated number of sites of 72 for this OES, the total number of workers expected for this
Page 300 of 313
-------
OES is 2,260. The estimated number of ONUs per site for this OES is 18, with a total number of ONUs
of 1,283.
Table Apx G-26. Number of Workers for Use of Automotive Lubricants
NAICS Code
Total Number
of Unique Sites
Number of
Workers/Site
Total Number
of Workers
Number of
ONUs/Site
Total Number
of ONUs
336412
24
47
1,118
39
943
811111
18
2
39
0.2
4
336340
4
55
221
16
65
332410
7
27
190
9
66
336310
15
31
472
9
140
33634
4
55
221
16
65
Total
72
31
2,260
18
1,283
G.27Use of Formulations Containing Formaldehyde in Automotive Care
Products
Five reporters in the 2016 CDR reported the use of formaldehyde in liquid automotive care products
(\ v U \ lo i ). Three of the reporters reported a maximum formaldehyde concentration of 1 to 30
percent by weight, and two reporters indicated a concentration of less than 1 percent by weight (U.S.
). In the 2020 CDR, four reporters reported the use of formaldehyde as a binder in exterior
car waxes, polishes, and coatings. One of these reporters indicated 100 percent of its PV was used for
exterior car waxes, polishes, and coatings, with a concentration of 1 to 30 percent ( 020a).
Due to CBI claims in the CDR, the exact volume of formaldehyde is unknown. According to 2019 U.S.
Census Bureau data indicated in the MRD, there are 147,152 automotive detailing sites (U.S. EPA.
2022b). Using TRI, NEI, and DMR, EPA assumes a total number of sites of 26. The MRD assumes
automotive detailing facilities operate 260 days per year; however, EPA does not expect formaldehyde
to be used every day at automotive detailing sites ( 1022b).
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during use of automotive care products ( . 2016; U.S.
Census Bureau. ). This approach involved the identification of relevant SOC codes within the BLS
data for the identified NAICS codes. Section 2.4 includes further details regarding methodology for
estimating the number of workers and ONUs per site. EPA identified 26 sites in NEI that potentially use
formaldehyde for automotive care products; however, EPA does not expect this to cover all uses of
formaldehyde for this exposure scenario. Therefore, EPA applied a bounding estimate using the NAICS
codes 441110 - New Car Dealers and 811192 - Car Washes to estimate a total of 37,346 sites, 339,218
workers, and 35,031 ONUs. Market data was not available on formaldehyde use in automotive care
products; therefore, this may overestimate the number of sites and workers that actually use
formaldehyde. The full list of NAICS codes assessed for this OES is listed in Table Apx G-27.
Page 301 of 313
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TableApx G-27. Number of Workers for Use of Formulations Containing Formaldehyde in
Automotive Care Products
NAICS Code
Total Number of
Establishments
Total Number of
Workers
Total Number of
ONUs
Number of
Workers/Site
Number of
ONUs/Site
441110
21,444
261,018
27,282
12
1
811192
15,902
78,199
7,749
5
0.5
Total
37,346
339,218
35,031
-
-
G.28Use of Fertilizers Containing Formaldehyde in Outdoors Including
Lawns
Three reporters reported processing formaldehyde as a reactant for fertilizers. Two reporters indicated a
commercial/consumer use of formaldehyde as an agricultural product. One of these facilities reported 3
percent of their PV for this use with a maximum concentration of 30 to 60 percent formaldehyde. The
other facility reported 32 percent of their PV for this use; however, the concentration is not known or
reasonably ascertainable (U.S. EPA. 2020a).
Due to CBI claims in CDR, the exact volume of formaldehyde is unknown; however, one site reported a
PV of 260,000 lb formaldehyde for incorporation into formulation in the agriculture, forestry, fishing,
and hunting industry sector ( 020a). Facility operating schedules may be highly variable due
to crop type, season, and climate.
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during use of fertilizer (V S HI S. 2*- n / v \ ^sus Bureau.
2015). This approach involved the identification of relevant SOC codes within the BLS data for the
identified NAICS codes. Section 2.4 includes further details regarding methodology for estimating the
number of workers and ONUs per site. EPA did not identify sites that use fertilizers containing
formaldehyde in release data; therefore, EPA applied a bounding estimate using the NAICS code
115112 - Soil Preparation, Planting, and Cultivating to estimate a total of 2,157 sites, 2,914 workers,
and 274 ONUs. Market data was not available on formaldehyde use in fertilizers; therefore, this may
overestimate the number of sites and workers that actually use fertilizer containing formaldehyde. The
full list of NAICS codes assessed for this OES is listed in TableApx G-28.
Table Apx G-28. Number of Workers for Use of Fertilizers containing Formaldehyde in Outdoors
including Lawns
NAICS Code
Total Number of
Establishments
Total Number of
Workers
Total Number of
ONUs
Number of
Workers/Site
Number of
ONUs/Site
115112
2,157
2,914
274
1
0.1
Total
2,157
2,914
274
-
-
G.29Use of Explosive Materials
The volume of formaldehyde present in explosive materials is unknown. Additionally, the number and
location of sites that use explosive materials containing formaldehyde are unknown. Using primarily
NAICS code 928110 - National Security, EPA estimates 344 sites. Due to a lack of information, EPA
does not present annual or daily site throughputs.
Page 302 of 313
-------
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during use of explosive materials (\ c. M < S. 2*-m , I v
Census Bureau. ). This approach involved the identification of relevant SOC codes within the BLS
data for the identified NAICS codes. Section 2.4 includes further details regarding methodology for
estimating the number of workers and ONUs per site. EPA assigned the NAICS code subsector 3329 -
Other Fabricated Metal Product Manufacturing and NAICS code 928110 - National Security for this
OES based on the mapping of OSHA data described in Appendix C.9. The full list of NAICS codes
assessed for this OES is listed in TableApx G-29. The estimated number of workers per site for use of
explosive materials is 32. Based on an estimated number of sites of 207 for this OES, the total number
of workers expected for this OES is 6,574. The estimated number of ONUs per site for this OES is 12,
with a total number of ONUs of 2,534.
Table Apx G-29. Number of Workers for Use of Explosive Materials
NAICS
Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number of
Workers
Number of
ONUs/Site
Total Number of
ONUs
928110
161
33
5,239
13
2,019
92811
24
33
781
13
301
332993
5
63
315
24
121
332994
13
11
145
4
56
332992
4
24
94
9
36
Total
207
6,574
2,534
G.30Use of Packaging, Paper, Plastics, and Hobby Products
The facility in the 2020 CDR reported a PV of 46,119 lb formaldehyde for commercial/consumer use in
paper articles ( 1020a). EPA uses site data from TRI, NEI, and DMR for NAICS code 453998
- All Other Miscellaneous Store Retailers (Except Tobacco Stores), 491110 - Postal Service, 492110 -
Local Messengers and Local Delivery, and 561910 - Packaging and Labeling Services to estimate a
number of sites of 28 for this OES. EPA assumes facilities that use these products typically operate 5
days/week, 50 weeks/year, or approximately 250 days/year.
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during use of packaging, paper, and hobby products (
2016; U.S. Census Bureau. 2015). This approach involved the identification of relevant SOC codes
within the BLS data for the identified NAICS codes. Section 2.4 includes further details regarding
methodology for estimating the number of workers and ONUs per site. EPA assigned the NAICS code
453998 - All Other Miscellaneous Store Retailers (except Tobacco Stores), 491110 - Postal Service,
492110 - Local Messengers and Local Delivery, and 561910 - Packaging and Labeling Services for this
OES based on the mapping of OSHA data described in Appendix C.9. The full list of NAICS codes
assessed for this OES is listed in Table Apx G-30. The estimated number of workers per site for use of
packaging, paper, and hobby products is 2. Based on an estimated number of sites of 28 for this OES,
the total number of workers expected for this OES is 42. The estimated number of ONUs per site for this
OES is 0.2, with a total number of ONUs of 7.
Page 303 of 313
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Table Apx G-30. Number of Workers for Use
of Packaging, Pa
)er, Plastics, and Hobby Products
NAICS
Total Number of
Number of
Total Number of
Number of
Total Number of
Code
Unique Sites
Workers/Site
Workers
ONUs/Site
ONUs
561910
6
3
19
0.4
3
492110
5
1
4
0.2
1
491110
12
1
17
0.2
3
453998
5
0.4
2
0.03
0.1
Total
28
-
42
-
7
G.31 Use of Craft Materials
The volume of formaldehyde present in craft materials is unknown. Additionally, the number and
location of sites that use paints, coatings, and adhesives containing formaldehyde are unknown. Using
NAICS codes 611110 - Elementary and Secondary Schools and 611610 - Fine Art Schools, EPA
estimates 190 sites reported in NEI. The Agency does not present daily or annual site throughputs. Using
the ESD on Automotive Spray Coating, facilities typically operate 250 days/year (OECD. 201 la).
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during use of craft materials (1; S HI S. 2016; U.S. Census
Bureau.: ). This approach involved the identification of relevant SOC codes within the BLS data for
the identified NAICS codes. Section 2.4 includes further details regarding methodology for estimating
the number of workers and ONUs per site. EPA assigned the NAICS codes 611110 - Elementary and
Secondary Schools and 611610 - Fine Art Schools for this OES based on the mapping of OSHA data
described in Appendix C. The full list of NAICS codes assessed for this OES is listed in Table Apx
G-31. The estimated number of workers per site for use of craft materials is 4. Based on an estimated
number of sites of 190 for this OES, the total number of workers expected for this OES is 771. The
estimated number of ONUs per site for this OES is 0.4, with a total number of ONUs of 76. Due to a
lack of readily available information, this estimate may not cover all sites that use formaldehyde in craft
materials.
Table Apx G-31. Number of Workers for Use of Craft Materia
s
NAICS
Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number of
Workers
Number of
ONUs/Site
Total Number of
ONUs
611110
188
4
771
0.4
76
611610
2
0.03
0.1
0.002
0.003
Total
190
-
771
-
76
G.32 Use of Printing Ink, Toner, and Colorant Products Containing
Formaldehyde
The GS on Manufacture and Use of Printing Inks indicates 29,738 use sites in 2007. According to the
GS, facilities typically operate 250 days/year ( ). The daily use rate of ink used for
flexographic printing is 1,800 kg/site-day, and facilities generally operate 300 days per year (
1999V
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during use of printing ink, toner, and colorant products (U.S.
Page 304 of 313
-------
i'i v _< < i , I v t ensus Bureau. I ). This approach involved the identification of relevant SOC
codes within the BLS data for the identified NAICS codes. Section 2.4 includes further details regarding
methodology for estimating the number of workers and ONUs per site.
EPA identified 239 sites in NEI that potentially use printing ink, toner, and colorant products containing
formaldehyde; however, EPA does not expect this to cover all uses of formaldehyde for this exposure
scenario. Therefore, EPA applied a bounding estimate using the NAICS subsectors 323 - Printing and
Related Support Activities and 511 - Publishing Industries (except Internet) to estimate a total of 71,648
sites, 112,842 workers, and 53,253 ONUs. Market data was not available on formaldehyde use in these
products; therefore, this may overestimate the number of sites and workers that actually use
formaldehyde-containing products. The full list of NAICS codes assessed for this OES is listed in
Table Apx G-32.
Table Apx G-32. Number of Workers for Use of Printing Ink, Toner, and Colorant Products
NAICS Code
Total Number of
Establishments
Total Number
of Workers
Total Number
of ONUs
Number of
Workers/Site
Number of
ONUs/site
323111
18,687
39,836
19,010
2
1
511110
7,165
3,850
1,621
1
0.2
323113
4,956
7,178
3,425
1
1
323117
447
2,543
1,214
6
3
511120
5,840
2,080
876
0.4
0.1
32311
24,090
49,557
23,649
2
1
323120
1,598
3,103
1,481
2
1
511140
886
440
185
0.5
0.2
511199
714
126
53
0.2
0.1
511191
100
280
118
3
1
51111
7,165
3,850
1,621
1
0.2
Total
71,648
112,842
53,253
-
-
G.33 Photo Processing Using Formulations Containing Formaldehyde
According to NICNAS, commercial film processing machines operate 4 to 5 hours per day, 5 days per
week (NICNAS. 20061
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during photo processing ( ;nsus Bureau.
2015). This approach involved the identification of relevant SOC codes within the BLS data for the
identified NAICS codes. Section 2.4 includes further details regarding methodology for estimating the
number of workers and ONUs per site.
EPA identified two sites in NEI that potentially use formulations containing formaldehyde for photo
processing; however, EPA does not expect this to cover all uses of formaldehyde for this exposure
scenario. Therefore, EPA applied a bounding estimate using the NAICS codes 512199 - Other Motion
Picture and Video Industries and 541922 - Commercial Photography to estimate a total of 3,951 sites,
357 workers, and 204 ONUs. Market data was not available on formaldehyde use in these products;
Page 305 of 313
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therefore, this may overestimate the number of sites and workers that actually use formaldehyde-
containing products. The full list of NAICS codes assessed for this OES is listed in TableApx G-33.
TableApx G-33. Number of Workers for Photo Processing Using Formulations Containing
Formaldehyt
e
NAICS Code
Total Number of
Unique Sites
Total Number of
Workers
Total Number of
ONUs
Number of
Workers/Site
Number of
ONUs/Site
541922
3,740
328
195
0.1
0.1
512199
211
29
9
0.1
0.04
Total
3,951
357
204
-
-
G.34 General Laboratory Use
In the 2020 CDR, there are four industrial processing and use reports indicating the downstream use of
formaldehyde in laboratory chemicals ( 020a). Two of the reporters indicated 20 percent of
their PV going toward incorporation into the formulation. The other two reporters indicated 80 percent
of their PV going toward repackaging. One reporter indicated 2 percent of its use in the
commercial/consumer use category for laboratory chemicals with a maximum formaldehyde
concentration of 1 to less than 30 percent ( )20a).
OSHA estimates approximately 12,000 laboratories use formaldehyde, including chemical, animal,
biomedical, and research laboratories (Gorisetal h")l)8). In TRI, NEI, and DMR, 1,635 laboratories
were identified.
The 2020 CDR indicates a PV of 324,000 lb of formaldehyde for laboratory use ( 20a). Due
to a lack of information, EPA does not present annual or daily formaldehyde site throughputs. The
Agency assumes that the daily throughput follows a distribution of 0.5 mL to 4,000 mL of formaldehyde
per site day based on the Use of Laboratory Chemicals GS ( 23d). The GS indicates that
facilities typically operate 260 days/year ( 23d). The GS also estimates the number of
operating days based on data from BLS' Occupational Employment Statistics and assumed shift
durations of 8-, 10-, and 12-hour shifts, yielding several operating days of 260 days/yr, 208 days/yr, and
174 days/yr, respectively (U.S. EPA. 2023d).
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during general laboratory use (\ c. S. 2^m / v \ »sus
Bureau.: ). This approach involved the identification of relevant SOC codes within the BLS data for
the identified NAICS codes. Section 2.4 includes further details regarding methodology for estimating
the number of workers and ONUs per site. EPA assigned the NAICS code subsectors 541 —
Professional, Scientific, and Technical Services, 611 - Educational Services, Ambulatory Health Care
Services, 621 - Ambulatory Health Care Services, 622 - Hospitals, and 927 - Space Research and
Technology for this OES based on the mapping of OSHA data described in Appendix C.9. The full list
of NAICS codes assessed for this OES is listed in TableApx G-34. The estimated number of workers
per site for general laboratory use is 11. Based on an estimated number of sites of 1,364 for this OES,
the total number of workers expected for this OES is 14,401. The estimated number of ONUs per site for
this OES is 8, with a total number of ONUs of 10.939.
Page 306 of 313
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Table Apx G-3^
. Number of Workers for General Laboratory Use
NAICS Code
Total Number
of Unique Sites
Number of
Workers/Site
Total Number
of Workers
Number of
ONUs/Site
Total Number
ofONUs
927110
8
4
32
5
38
61131
52
14
748
19
975
541380
46
1
44
9
398
611310
319
14
4,587
19
5,980
54171
19
1
19
9
180
622110
643
13
8,410
4
2,287
541940
27
0.3
9
0.2
5
541715
42
1
47
10
437
541713
8
1
5
6
48
611210
30
11
327
3
88
541720
20
1
10
5
94
61121
1
11
11
3
3
541990
8
0.2
1
0.1
1
541714
55
1
36
6
331
6115
1
1
1
0.1
0.1
621111
25
0.04
1
0.01
0.2
611519
4
1
2
0.1
0.4
621511
10
0.1
1
0.2
2
622310
14
3
40
3
38
6113
1
14
14
19
19
621491
8
0.3
2
0.1
0.4
621112
12
0.01
0.2
0.003
0.03
621210
3
0.1
0.2
0.0004
0.001
621399
2
0.03
0.1
0.0004
0.001
621492
2
0.1
0.2
0.02
0.04
6221
4
13
52
4
14
Total
1,364
14,401
10,939
G.35 Worker Handling of Wastes
As per 2018 TRI reports, 715 facilities managed, in total, over 132 million lb of formaldehyde as waste
( 2017b). Of this total, approximately 70 million lb were treated, nearly 35 million lb were
recycled, over 20 million lb were released or otherwise disposed of, and over 7 million lb were burned
for energy recovery. Of the 70 million lb of formaldehyde that were treated, about 65 million lb were
treated on-site, and 5 million lb were treated off-site. Similarly, 99 percent of the formaldehyde waste
that was recycled was recycled on-site, and 93 percent of the formaldehyde waste that was used for
energy recovery was combusted on-site.
Page 307 of 313
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Nearly three-quarters of the formaldehyde that was disposed of or released occurred to land, the majority
of which (14.2 million lb) was disposed of on-site to Class I underground injection wells, and about
240,000 lb was disposed of off-site to Class I underground injection wells. Over 4.6 million lb of
formaldehyde were released to air; 93 percent of which was in the form of point source air (stack)
emissions. Releases to water and other releases not mentioned above accounted for small amounts of the
total releases at just 1 and 2 percent, respectively ( ).
Using TRI, NEI, and DMR data, EPA identified 1,123 sites specifically in the waste collection and
waste management industries.
EPA used BLS and SUSB data specific to the OES to estimate the number of workers and ONUs per
site potentially exposed to formaldehyde during worker handling of wastes (ll$ JILS .^01 , * v
Census Bureau. 2015). This approach involved the identification of relevant SOC codes within the BLS
data for the identified NAICS codes. Section 2.4 includes further details regarding methodology for
estimating the number of workers and ONUs per site. EPA assigned the NAICS code subsectors 221 -
Utilities, 325 - Chemical Manufacturing, 562 - Waste Management and Remediation Services. The full
list of NAICS codes assessed for this OES is listed in TableApx G-35. The estimated number of
workers per site for worker handling of wastes is 4. Based on an estimated 1,003 number of sites for this
OES outlined in Section 4.36.2, the total number of workers expected for this OES is 3,519. The
estimated number of ONUs per site for this OES is 2, with a total number of ONUs of 1,768.
Table Apx G-35. Number of Workers for Worker Handling of Waste
NAICS
Code
Total Number of
Unique Sites
Number of
Workers/Site
Total Number of
Workers
Number of
ONUs/Site
Total Number of
ONUs
562211
49
9
441
5
253
562212
219
3
756
2
434
562219
51
3
142
2
81
562111
16
1
20
0.1
2
221320
361
2
786
1
318
22132
237
2
516
1
209
562213
47
13
623
8
357
2213
2
2
4
1
2
562910
8
2
18
2
14
562119
1
1
1
0.1
0.1
56211
2
1
2
0.1
0.3
562998
3
1
4
1
3
325180
1
25
25
12
12
325110
1
64
64
30
30
325120
2
14
28
7
13
325998
1
14
14
5
5
325194
1
34
34
16
16
325199
1
39
39
18
18
Total
1,003
3,519
1,768
Page 308 of 313
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Appendix H EXAMPLE OF ESTIMATING NUMBER OF WORKERS
AND OCCUPATIONAL NON-USERS
This appendix summarizes the methods that EPA/OPPT used to estimate the number of workers who are
potentially exposed to formaldehyde in each of its conditions of use. The method consists of the
following steps:
1. Check relevant ESDs and GSs for estimates on the number of workers potentially exposed.
2. Identify the NAICS codes for the industry sectors associated with each condition of use.
3. Estimate total employment by industry/occupation combination using the Bureau of Labor
Statistics" Occupational Employment Statistics data ( >. 2016).
4. Refine the Occupational Employment Statistics estimates where they are not sufficiently
granular by using the U.S. Census' ( nsus Bureau. 2015) Statistics of U.S. Businesses
(SUSB) data on total employment by 6-digit NAICS.
5. Estimate the percentage of employees likely to be using formaldehyde instead of other chemicals
{i.e., the market penetration of formaldehyde in the condition of use).
6. Estimate the number of sites and number of potentially exposed employees per site.
7. Estimate the number of potentially exposed employees within the COU.
Step 1: Identifying Affected NAICS Codes
As a first step, EPA/OPPT identified NAICS industry codes associated with each condition of use.
EPA/OPPT generally identified NAICS industry codes for a COU by:
• Querying the sus Bureau's NAICS Search tool using keywords associated with each
condition of use to identify NAICS codes with descriptions that match the condition of use.
• Referencing EPA/OPPT GSs and Organisation for Economic Co-operation and Development
(OECD) ESDs for a COU to identify NAICS codes cited by the GS or ESD.
• Reviewing CDR data for the chemical, identifying the industrial sector codes reported for
downstream industrial uses, and matching those industrial sector codes to NAICS codes using
TableApx F-2 provided in the CDR reporting instructions (U.S. EPA, 2020).
Each COU section in the main body of this assessment identifies the NAICS codes EPA/OPPT
identified for the respective condition of use.
Step 2: Estimating Total Employment by Industry and Occupation
BLS's ( ) OES data provide employment data for workers in specific industries and
occupations. The industries are classified by NAICS codes (identified previously), and occupations are
classified by Standard Occupational Classification (SOC) codes.
Among the relevant NAICS codes (identified previously), EPA/OPPT reviewed the occupation
description and identified those occupations (SOC codes) where workers are potentially exposed to
formaldehyde. Table Apx H-l shows the SOC codes EPA/OPPT classified as occupations potentially
exposed to formaldehyde. These occupations are classified as workers (W) and occupational non-users
(O). All other SOC codes are assumed to represent occupations where exposure is unlikely.
Page 309 of 313
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TableApx H-l. SOCs with Worker and ONU Designations for All Conditions of Use Except Dry
Cleaning
SOC
Occupation
Designation
11-9020
Construction Managers
O
17-2000
Engineers
O
17-3000
Drafters, Engineering Technicians, and Mapping Technicians
0
19-2031
Chemists
0
19-4000
Life, Physical, and Social Science Technicians
0
47-1000
Supervisors of Construction and Extraction Workers
0
47-2000
Construction Trades Workers
w
49-1000
Supervisors of Installation, Maintenance, and Repair Workers
0
49-2000
Electrical and Electronic Equipment Mechanics, Installers, and Repairers
w
49-3000
Vehicle and Mobile Equipment Mechanics, Installers, and Repairers
w
49-9010
Control and Valve Installers and Repairers
w
49-9020
Heating, Air Conditioning, and Refrigeration Mechanics and Installers
w
49-9040
Industrial Machinery Installation, Repair, and Maintenance Workers
w
49-9060
Precision Instrument and Equipment Repairers
w
49-9070
Maintenance and Repair Workers, General
w
49-9090
Miscellaneous Installation, Maintenance, and Repair Workers
w
51-1000
Supervisors of Production Workers
0
51-2000
Assemblers and Fabricators
w
51-4020
Forming Machine Setters, Operators, and Tenders, Metal and Plastic
w
51-6010
Laundry and Dry-Cleaning Workers
w
51-6020
Pressers, Textile, Garment, and Related Materials
w
51-6030
Sewing Machine Operators
0
51-6040
Shoe and Leather Workers
0
51-6050
Tailors, Dressmakers, and Sewers
0
51-6090
Miscellaneous Textile, Apparel, and Furnishings Workers
0
51-8020
Stationary Engineers and Boiler Operators
w
51-8090
Miscellaneous Plant and System Operators
w
51-9000
Other Production Occupations
w
W = worker designation; O = ONU designation
For dry cleaning facilities, due to the unique nature of work expected at these facilities and that different
workers may be expected to share among activities with higher exposure potential (e.g., unloading the
dry-cleaning machine, pressing/finishing a dry-cleaned load), EPA/OPPT made different SOC code
worker and ONU assignments for this condition of use. Table Apx H-2 summarizes the SOC codes with
worker and ONU designations used for dry cleaning facilities.
Page 310 of 313
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Table Apx H-2. SOCs with Worker and ONU Designations for Dry Cleaning Facilit
ies
SOC
Occupation
Designation
41-2000
Retail Sales Workers
O
49-9040
Industrial Machinery Installation, Repair, and Maintenance Workers
W
49-9070
Maintenance and Repair Workers, General
w
49-9090
Miscellaneous Installation, Maintenance, and Repair Workers
w
51-6010
Laundry and Dry-Cleaning Workers
w
51-6020
Pressers, Textile, Garment, and Related Materials
w
51-6030
Sewing Machine Operators
0
51-6040
Shoe and Leather Workers
0
51-6050
Tailors, Dressmakers, and Sewers
0
51-6090
Miscellaneous Textile, Apparel, and Furnishings Workers
0
W = worker designation; O = ONU designation
After identifying relevant NAICS and SOC codes, EPA/OPPT used BLS data to determine total
employment by industry and by occupation based on the NAICS and SOC combinations. For example,
there are 110,640 employees associated with 4-digit NAICS 8123 (Drycleaning and Laundry Services)
and SOC 51-6010 (Laundry and Dry-Cleaning Workers).
Using a combination of NAICS and SOC codes to estimate total employment provides more accurate
estimates for the number of workers than using NAICS codes alone. Using only NAICS codes to
estimate number of workers typically result in an overestimate, because not all workers employed in that
industry sector will be exposed. However, in some cases, BLS only provide employment data at the 4-
digit or 5-digit NAICS level; therefore, further refinement of this approach may be needed (see next
step).
Step 3: Refining Employment Estimates to Account for lack of NA ICS Granularity
The third step in EPA/OPPT's methodology was to further refine the employment estimates by using
total employment data in the U.S. Census Bureau's (1; S Census Bureau. 2015) SUSB. In some cases,
BLS OES's occupation-specific data are only available at the 4- or 5-digit NAICS level, whereas the
SUSB data are available at the 6-digit level (but are not occupation-specific). Identifying specific 6-digit
NAICS will ensure that only industries with potential formaldehyde exposure are included. As an
example, OES data are available for the 4-digit NAICS 8123 Drycleaning and Laundry Services, which
includes the following 6-digit NAICS:
• NAICS 812310 Coin-Operated Laundries and Drycleaners;
• NAICS 812320 Drycleaning and Laundry Services (except Coin-Operated);
• NAICS 812331 Linen Supply; and
• NAICS 812332 Industrial Launderers.
In this example, only NAICS 812320 is of interest. The Census data allow EPA/OPPT to calculate
employment in the specific 6-digit NAICS of interest as a percentage of employment in the BLS 4-digit
NAICS.
The 6-digit NAICS 812320 comprises 46 percent of total employment under the 4-digit NAICS 8123.
This percentage can be multiplied by the occupation-specific employment estimates given in the BLS
OES data to further refine our estimates of the number of employees with potential exposure.
Table Apx H-3 illustrates this granularity adjustment for NAICS 812320.
Page 311 of 313
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TableApx H-3. Estimated Number of Potentially Exposed Workers and ONUs under NAICS
812320
NAICS
SOC
Code
SOC Description
Occupation
Designation
Employment by
SOC at 4-Digit
NAICS Level
% of Total
Employment
Estim. Employment
by SOC at 6-digit
NAICS Level
8123
41-2000
Retail Sales Workers
O
44,500
46.0
20,459
8123
49-9040
Industrial Machinery
Installation, Repair, and
Maintenance Workers
w
1,790
46.0
823
8123
49-9070
Maintenance and Repair
Workers, General
w
3,260
46.0
1,499
8123
49-9090
Miscellaneous Installation,
Maintenance, and Repair
Workers
w
1,080
46.0
497
8123
51-6010
Laundry and Dry-Cleaning
Workers
w
110,640
46.0
50,867
8123
51-6020
Pressers, Textile, Garment,
and Related Materials
w
40,250
46.0
18,505
8123
51-6030
Sewing Machine Operators
0
1,660
46.0
763
8123
51-6040
Shoe and Leather Workers
0
Not reported for t
lis NAICS coc
e
8123
51-6050
Tailors, Dressmakers, and
Sewers
0
2,890
46.0
1,329
8123
51-6090
Miscellaneous Textile,
Apparel, and Furnishings
Workers
0
0
46.0
0
Total Potentially Exposed Employees
206,070
94,740
Total Workers
72,190
Total ONUs
22,551
Source: US Census. 2015 ("U.S. Census Bureau. 2015): BLS. 2016 ("U.S. BLS. 2016s)
Note: numbers may not sum exactly due to rounding.
W = worker; O = occupational non-user
Step 4: Estimating the Percentage of Workers Using Formaldehyde Instead of Other Chemicals
In the final step, EPA/OPPT accounted for the market share by applying a factor to the number of
workers determined in Step 3. This accounts for the fact that formaldehyde may be only one of multiple
chemicals used for the applications of interest. EPA/OPPT did not identify market penetration data for
any conditions of use. In the absence of market penetration data for a given condition of use, EPA/OPPT
assumed formaldehyde may be used at up to all sites and by up to all workers calculated in this method
as a bounding estimate. This assumes a market penetration of 100 percent.
Step 5: Estimating the Number of Workers per Site
EPA/OPPT calculated the number of workers and ONUs in each industry/occupation combination using
the formula below (granularity adjustment is only applicable where SOC data are not available at the 6-
digit NAICS level):
Number of Workers or ONUs in NAICS/SOC (Step 2)
Granularity Adjustment Percentage (Step 3) = Number of Workers or ONUs in the
Industry/Occupation Combination
Page 312 of 313
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EPA/OPPT then estimated the total number of establishments by obtaining the number of establishments
reported in the U.S. Census Bureau's SUSB (U.S. Census Bureau. 2015) data at the 6-digit NAICS
level.
Next, EPA/OPPT summed the number of workers and ONUs over all occupations within a NAICS code
and divided these sums by the number of establishments in the NAICS code to calculate the average
number of workers and ONUs per site.
Step 6: Estimating the Number of Workers and Sites for a Condition of Use
EPA/OPPT estimated the number of workers and occupational non-users potentially exposed to
formaldehyde and the number of sites that use formaldehyde in a given condition of use through the
following steps:
6. A. Obtaining the total number of establishments by:
i. Obtaining the number of establishments from SUSB (\] S Census Bureau. 2015) at the 6-
digit NAICS level (Step 5) for each NAICS code in the condition of use and summing
these values; or
ii. Obtaining the number of establishments from the TRI, DMR, NEI, or literature for the
condition of use.
6.B. Estimating the number of establishments that use formaldehyde by taking the total number of
establishments from Step 6. A and multiplying it by the market penetration factor from Step
4.
6.C. Estimating the number of workers and occupational non-users potentially exposed to
formaldehyde by taking the number of establishments calculated in Step 6.B and multiplying
it by the average number of workers and ONUs per site from Step 5.
Page 313 of 313
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