Comment Log Display

On behalf of Kaiser Permanente I would like to thank the California
Air Resources Board (CARB) for their excellent work in researching
the issues associated with formaldehyde exposure and risk.  As one
of the largest employers in California and with more 6.3 million
members of our health plan, Kaiser Permanente is extremely
concerned with the health impact of toxic materials to our staff,
patients, and the communities we serve.  We commend the CARB for
raising the dangers of formaldehyde exposure to the light of
public discourse. 

Because composite wood products are made using large amounts of
urea formaldehyde resins as a binder, these products create
formaldehyde emissions that are toxic. The CARB estimated that as
much as 800 tons of formaldehyde were emitted in California from
composite wood products in 2002 (based on products consumed
between 1983 and 2002) leading to hazardous concentration levels
in the air in buildings, including the hundreds of clinics,
hospitals, and other buildings in California owned by Kaiser
Permanente. California has recognized that there is no known safe
level of formaldehyde, as the Office of Environmental Health
Hazards Assessment (OEHHA) determined that the safe reference
exposure level (CREL) for formaldehyde was lower than the level of
formaldehyde already in the ambient air. 

Less than three years ago, in 2004, the World Health
Organization’s International Agency for Research on Cancer (IARC)
updated its report on formaldehyde. Based on new information from
studies of persons exposed to formaldehyde, IARC changed its
position that formaldehyde was a "probable carcinogen" to conclude
that formaldehyde is "carcinogenic to humans".  And as we all know
cancer is one of the leading causes of illness and deaths in
California and in the nation.  In addition to IARC, other national
and international regulatory agencies have determined that
formaldehyde is a public health and occupational concern. The list
includes The National Toxicology Program (NTP),  The National
Institute for Occupational Safety and Health (NIOSH) ,and The
Association of Occupational and Environmental  Clinics (AOEC). 
The EPA Integrated Risk Information System (IRIS) found that
formaldehyde is a probable human carcinogen in animal studies.
Moreover, the EPA under the Clean Air Act, has concluded that
formaldehyde is a hazardous air pollutant. 

Kaiser Permanente has long understood the connection between
environmental hazards and health outcomes.  We have been very
active in our attempts to remove toxic materials from our
facilities that pose a risk to our staff and patients.  We have
been diligent in our efforts to evaluate the products we purchase
and materials we use for their impact on workplace, patient, and
environmental safety.  The result of this effort is that all our
facilities are virtually mercury free and we have removed other
persistent bioaccumulative toxins such as DEHP and polyvinyl
chloride from most of the products we purchase.  Where less toxic
alternatives have not existed we have pushed the market place to
develop safer products. 

Based on the plethora of information raising concerns about
formaldehyde exposure in occupational settings, in buildings, and
in ambient air, Kaiser Permanente has taken the position that it
is one of our chemicals of concern. This has meant that Kaiser
Permanente has researched alternative products that do not contain
formaldehyde.  Our overall goal has been to replace products that
pose a danger to our staff, patients and the public  with safer
materials without added cost.  

We have an active campaign to reduce formaldehyde in the
furniture, fabric, casework, and building insulation we use in our
facilities.  However, the cost of many of the alternatives are
significantly higher than those products containing formaldehyde. 
We find this primarily due to these alternatives not having a
significant enough market share to be cost competitive with those
products that pose a health risk. 

If we look at the larger picture and include the health care cost
to the State as a whole in treating cancer patients and others
whose condition may be impacted by their exposure to formaldehyde,
 then the cost of inaction is far greater to all of us.  We urge
CARB to adopt stricter guidelines for formaldehyde levels as this
set the climate for manufacturers to develop formaldehyde-free
alternatives that will  be competitive in the marketplace.  As a
large purchaser in California we can't make this market change to
safer materials without your support.  For the sake of the health
of all of us we strongly support CARB's efforts to protect
Californians from this known carcinogen. 

Thank you,
Tom Cooper
Kaiser Permanente
Chairperson, High Performance Buildings Committee