First Name | Hal |
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Last Name | Levin |
Email Address | hal.levin@buildingecology.com |
Affiliation | |
Subject | Comp wood regulation |
Comment | Further comments on proposed regulation; 1. ASTM Standard E1333 is inappropriate for the regulation. The sensitivity of the test is intended to be appropriate to determine airborne concentrations in the range of 0.3 ppm. The proposed regulations would limit concentrations to values as low as 0.05 ppm. A more sensitive test is required for compliance. I suggest eliminating the chromotropic acid analytical method and using only DNPH for the analysis described in the standard. It must be recognized that E1333 was written for compliance with the HUD standard which limits concentrations to 0.3 ppm. DNPH is included as an alternate in the standard, but it should be the required method. There is an ASTM standard for the DNPH method. 2. I do not believe that the final regulatory targets in years 2011 and 2012 of 0.11 and 0.13 for MDF and thin MDF respectively are sufficiently protective of the population. The installation of products with these emissions in residential bedrooms of energy efficient homes - tightly sealed against air leakage and without any specific outdoor air ventilatioon system -- where ventilation rates may be significantly lower than the 0.5 air changes per hour in the test chamber means occupants will be exposed to concentrations well in excess of 0.1 ppm. Given the abundant evidence of the toxicity and the listing of formaldehyde as a carcinogen, I believe the limit should be based on a target concentration no higher than that established by OEHHA for workplace exposure which is only intended to protect workers during a 40-hour work week. Far more time could be spent in a residence thus requiring a far lower target concentration or concentration limit. 3. I recommend a concentration target limit that is based on an assumption of 0.25 air changes per hour and an emission rate that does not result in concentrations exceeding 0.027 ppm formaldehyde under realistic modeling scenarios. Assume MDF will be the core of a composite flooring material with a loading ratio of 0.42 m^2/m^3 and cabinetry or closet doors with a loading ratio of 0.25 m^2/m^3. An emission rate far below the proposed limits will be required to provide protection in energy efficient residential environments with typical ventilation rates below 0.5 air changes per hour. Even at 0.5 ach, concentrations of 100 ppb or above are simply unacceptable given the health effects data on formaldehyde exposure. Hal Levin Building Ecology Research Group 2548 Empire Grade, Santa Cruz, CA 95060 1.831.425.3946 |
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Date and Time Comment Was Submitted | 2007-04-25 09:11:46 |
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