Comment Log Display

1. The target levels of formaldehyde emissions for this regulation
are far too high. It makes very little sense to implement this
regulatory process without achieving a far more substantial
difference in the ultimate exposures of the population.
Formaldehyde is a carcinogen and irritant and a more vigorous
effort to control population exposure from CWP is warranted.
Substantial reductions in formaldehyde emissions from CWPs have
been achieved over the past 25 years through more careful
formulation of adhesives and through improved quality control in
the CWP manufacturing process. Further reduction is technically
feasible and should not be dismissed as the preferable option.

2. Alternative (non-formaldehyde based) adhesives are also
available for the proposed regulated products in which
formaldehyde is widely used. It is  difficult to justify continued
population exposure to formaldehyde at the levels contemplated in
the proposed regulated in light of this fact and the carcinogen
status of formaldehyde.

3. State office buildings (Capitol Area East End Project) have
been built during the past five years where far lower criteria
were used for formaldehyde emissions. Proportional reductions of
more than a factor of three would be appropriate based on the
standards used for the State's own office buildings. 

4. The economic analysis is flawed in that it does not take into
account the cost of ventilation necessary to reduce airborne
concentrations of formaldehyde by dilution ventilation to achieve
levels that could be achieved more effectively at the one-time
first cost of lower emitting CWP. This ventilation has an impact
not only on operating costs but also on carbon emissions due to
electric power plant operation and emissions. For example, if
emissions were reduced by a factor of four, roughly only
one-fourth the outdoor air would be necessary to dilute the
concentrations in the air according to an oversimplified mass
balance model to achieve the same indoor air concentration. Since
the emissions from CWP generally have half-lives of several years,
this means that several years worth of significantly increased
ventilation would be necessary to provide the same protection to
the public as would be provided by a reduction in the intial
source strength of formaldehyde emissions. 

5. CWPs are one of if not the dominant sources of formaldehyde
emissions to the indoor environment, especially but not
exclusively in residential environments. Outdoor air ventilation
is not generally common or adequate there, mostly provided by
incidental leakage of the building exterior "envelope." While
energy cost and carbon emission limitations are important current
and future constraints on energy consumption to ventilate and to
heat and cool outdoor air used for ventilation, the incentives for
source strength reduction are likely to increase considerably in
the coming years in order to achieve a given level of general
population exposure to indoor source pollutants. 

6. CARB has had a relatively forward-looking guideline and target
for indoor formaldehyde concentrations for many years now. This
proposed regulation is far less stringent that what would be
necessary to achieve that target.  CARB should take more effective
action now on this well-known and widely-distributed substance to
reduce the future costs of reduction by ventilation or removal and
replacement of strong sources, especially the widely-used CWP.