Formaldehyde, a colorless and pungent-smelling gas, has long been a staple in various industrial applications. From its role in the production of resins and adhesives to its use as a preservative in medical laboratories, this versatile compound is both ubiquitous and indispensable. However, its widespread use has also raised health and environmental concerns. As we approach February, a month dedicated to raising awareness about chemical safety, it is crucial to delve into the multifaceted world of formaldehyde.

The United States (U.S.) Environmental Protection Agency (EPA) final risk evaluation of formaldehyde under the Toxic Substances Control Act (TSCA) has significant implications for the plumbing and mechanical industries. The TSCA risk evaluation looked at the multiple uses of formaldehyde to determine if there are unreasonable risks to human health or the environment. In this review, U.S. EPA did not identify any environmental risks from formaldehyde. U.S. EPA did identify 58 uses that present an unreasonable risk of injury to human health and is now mandated under TSCA to initiate regulations to address the identified human health hazards.

The impact of a second Trump administration on future formaldehyde regulation efforts remains uncertain. Trump's first administration's actions suggest a possible rollback of regulatory efforts, which could manifest as a reopening and revision of the TSCA risk evaluation. In the meantime, let's jump into an assessment of the TSCA risk evaluation's impact on manufacturing.

U.S. EPA's Unreasonable Risk Uses

Below is a curated list of the uses identified in the TSCA report that are the most relevant to the plumbing and mechanical industries:

1. Manufacturing (domestic and import)
2. As a process reactant in:
1. adhesives and sealant chemicals in plastic and resin manufacturing;
2. paint and coating manufacturing;
3. As a process reactant in an intermediate in:
1. soap, cleaning compound, and toilet preparation manufacturing;
2. plastic materials and resin manufacturing;
3. paint and coating manufacturing;
4. plastic products manufacturing;
5. synthetic rubber manufacturing;
4. Incorporation into an article in:
1. additive in rubber product manufacturing;
2. plastic material and resin manufacturing ;
3. construction;
5. Incorporation into formulations, mixtures, or reaction products in:
1. paint additives and coating additives not covered by other categories;
2. plastic material and resin manufacturing;
3. wholesale and retail trade;
4. surface active agents in plastic material and resin manufacturing;
5. plating agents and surface treating agents in chemical product and preparation manufacturing;
6. soap, cleaning compound, and toilet preparation manufacturing;
6. Industrial use of chemical substances in:
1. oxidizing/reducing agent;
2. processing aids not covered by other categories;
7. Commercial use in:
1. stone, plaster, cement, glass ceramic, metal, and rubber furniture & furnishings products;
2. water treatment products;
3. stone, plaster, cement, glass, ceramic, and metal construction and building materials covering large surface areas;
8. Consumer use in:
1. stone, plaster, cement, glass, ceramic, metal, or rubber furniture & furnishings products
2. adhesives and sealant;
3. paint and coatings;
4. metal, stone, plaster, cement, glass, and ceramic construction and building materials covering large surface areas; and
5. plastic and rubber products.

The extensive list of uses above has the potential to affect all aspects of plumbing and mechanical manufacturing. I will focus on potential impacts to 1) facility investments and operations and 2) product development and innovation.

Facility Investments and Operations

Facilities should expect increased costs for capital investments, the development of specialized training modules on formaldehyde handling and exposure prevention, personal protective equipment (PPE) requirements, compliance monitoring and reporting, and the implementation of emergency response procedures for formaldehyde-related incidents.

To address worker exposure concerns, manufacturing facilities may need to implement enhanced ventilation systems in areas where formaldehyde-containing materials are used, redesign production lines to minimize worker contact with formaldehyde-based components, introduce automated processes for handling formaldehyde-containing materials, and installation of real-time air quality monitoring systems.

Product Development and Innovation

Existing products may require evaluation for formaldehyde-containing materials, which could require product reformulations. New and existing products may have to be assessed for alternate materials with lower formaldehyde content or developing new product lines low in formaldehyde emissions. These changes could affect product performance and costs, necessitating extensive research and development (R&D) efforts.

Increased R&D focus may be needed to explore formaldehyde-free alternatives, develop new manufacturing techniques that reduce or eliminate formaldehyde use, and investigate novel materials that can replace formaldehyde-based products or processes without compromising performance.

Additionally, there will be an increased need for disclosure of suppliers' formaldehyde management practices, potential diversification of the supplier base to include those offering low-formaldehyde or formaldehyde-free alternatives, collaboration with suppliers on developing compliant materials and components, and possible renegotiation of contracts to account for new material specifications and compliance requirements.

What can you do?

The U.S. EPA's regulatory work is slated to continue in 2025, with opportunities for public comment. For those looking for a customized analysis or seeking assistance in making public comments, call us at Regulosity. Our team specializes in detailed and personalized assessments to help you navigate and engage with the complexities of the regulatory framework.