Panel on Formaldehyde Emissions from Composite Wood Products

[Guest guest]

For those concerned about indoor exposures to formaldehyde:

What I have observed in my consulting practice is that new homes constructed with OSB sheathing and subflooring, truss joist I-beams (TJIs), and microlam girders contain airborne volatile chemicals that cause neurologic/irritant symptoms in occupants.

New formaldehyde-emitting particleboard cabinets and subflooring and medium density fiberboard (MDF) are materials better known to be problematic.

It seems that new EPA regulations for composite wood products will not even address the common composite wood products that are causing problems for my clients -- which include OSB, TJIs, and microlams. Industry is interested in preventing imports of competing particleboard, MDF, and hardwood plywood products but EPA and industry seemingly do not recognize, or want to acknowledge, that the other composite wood materials being used in high-end housing today are also a problem. They are going to selectively regulate certain composite wood products but not others.

Furthermore, the EPA proposed "emissions rate" is not an emissions rate at all because it is in units of parts per million or billion. PPM is a concentration in air, not an emissions rate, and determined by multiple factors, including ventilation. An emissions rate must be in units of mass per surface area per time period to be intercomparable between materials. In addition, emissions from some materials will continue for much longer time periods than others.

There even is confusion in wording on the EPA website about whether the regulations are supposed to address "pressed wood products" or "composite wood products". Something smells funny to me about these new selective EPA regulations and industry's cooperation with EPA on them.

http://www.epa.gov/opptintr/chemtest/formaldehyde/index.html

http://www.epa.gov/sbrefa/formaldehyde.htm

Steve Temes

AirWays Environmental Services

Red Bank, NJ

[Guest guest]

Steve:

A few questions:

What neurologic symptoms have you noted in your clients in homes with OSB

sheeting?

Are these acute or chronic symptoms?

Have these observed (acute or chronic) symptoms been diagnosed by a physician?

If so, what was the VOC involved and what was the exposure concentration?

How were you able to isolate building materials as the source of the VOC issue

considering all the other common VOC emitters that consumers introduce into

their indoor environment?

On average, what percentage of your clients are suffering neurologic/irritant

symptoms?

Thanks for your feedback,

Will

>

> For those concerned about indoor exposures to formaldehyde:

>

> What I have observed in my consulting practice is that new homes

> constructed with OSB sheathing and subflooring, truss joist I-beams (TJIs),

and

> microlam girders contain airborne volatile chemicals that cause

> neurologic/irritant symptoms in occupants.

>

> New formaldehyde-emitting particleboard cabinets and subflooring and medium

> density fiberboard (MDF) are materials better known to be problematic.

>

> It seems that new EPA regulations for composite wood products will not even

> address the common composite wood products that are causing problems for my

> clients -- which include OSB, TJIs, and microlams. Industry is interested

> in preventing imports of competing particleboard, MDF, and hardwood plywood

> products but EPA and industry seemingly do not recognize, or want to

> acknowledge, that the other composite wood materials being used in high-end

housing

> today are also a problem. They are going to selectively regulate certain

> composite wood products but not others.

>

> Furthermore, the EPA proposed " emissions rate " is not an emissions rate at

> all because it is in units of parts per million or billion. PPM is a

> concentration in air, not an emissions rate, and determined by multiple

factors,

> including ventilation. An emissions rate must be in units of mass per

> surface area per time period to be intercomparable between materials. In

> addition, emissions from some materials will continue for much longer time

periods

> than others.

>

> There even is confusion in wording on the EPA website about whether the

> regulations are supposed to address " pressed wood products " or " composite wood

> products " . Something smells funny to me about these new selective EPA

> regulations and industry's cooperation with EPA on them.

>

> http://www.epa.gov/opptintr/chemtest/formaldehyde/index.html

>

> http://www.epa.gov/sbrefa/formaldehyde.htm

>

> Steve Temes

> AirWays Environmental Services

> Red Bank, NJ

>

[Guest guest]

Yes we are working for reasonable ventilation

modeling rates for residential scenarios in the development of the next version

of the California 01350 VOC emissions standard. 01350 was of course developed for

commercial buildings with even higher ventilation rates so is totally inappropriate

for residential settings. The state gets that and proposed for Version 1.1 a 0.26

ACH based on Bud Offerman’s study of 106 new California houses (he found

a median of 0.26 SCH and a minimum of 0.09 (lookup Ventilation and Indoor Air

Quality in New Homes at http://www.arb.ca.gov/research/apr/past/indoor.htm#Exposure

)) Industry is fighting it.

- Tom

From:

iequality [mailto:iequality ] On Behalf Of Jim H. White SSC

Sent: Wednesday, October 27, 2010

9:08 AM

To: iequality

Subject: Re: Re: Panel

on Formaldehyde Emissions from Composite Wood Products

Will

Consultants such as Steve (and myself, now that I am out on

my own) do not get paid to measure contaminants but to identify the likely

source of problems and the best/cheapest way to solve them.

It is too bad that there was not more funding for decent

research on source strengths (your list of questions would be a great start for

a good study), but the support for that research evaporated when industry

associations convinced all levels of government that industry is the engine of

the economy; that is a worse lie than Hitler ever told - we, the consuming

public who believe that they can risk buying what the want and need are the

engine.

I am all with Steve on the existing standards not measuring

source strengths, but only chamber concentrations under optimistic ventilation

and loading conditions. The industry says that we (consultants and consumers)

could not understand or use source strengths; that is true of most consumers

but not of most consultants. Has anyone noticed that suggested residential

ventilation rates are set at close to 0.25 AC/h (with the capability of double

that) but that chamber rates are set at 0.5? I seldom saw 0.5 AC/h when I was

having field tests done and 0.1 was not unusual.

Jim H. White SSC

Re:

Panel on Formaldehyde Emissions from Composite Wood Products

Steve:

A few questions:

What neurologic symptoms have you noted in your clients in homes with OSB

sheeting?

Are these acute or chronic symptoms?

Have these observed (acute or chronic) symptoms been diagnosed by a physician?

If so, what was the VOC involved and what was the exposure concentration?

How were you able to isolate building materials as the source of the VOC issue

considering all the other common VOC emitters that consumers introduce into

their indoor environment?

On average, what percentage of your clients are suffering neurologic/irritant

symptoms?

Thanks for your feedback,

Will

>

> For those concerned about indoor exposures to formaldehyde:

>

> What I have observed in my consulting practice is that new homes

> constructed with OSB sheathing and subflooring, truss joist I-beams

(TJIs), and

> microlam girders contain airborne volatile chemicals that cause

> neurologic/irritant symptoms in occupants.

>

> New formaldehyde-emitting particleboard cabinets and subflooring and

medium

> density fiberboard (MDF) are materials better known to be problematic.

>

> It seems that new EPA regulations for composite wood products will not

even

> address the common composite wood products that are causing problems for

my

> clients -- which include OSB, TJIs, and microlams. Industry is interested

> in preventing imports of competing particleboard, MDF, and hardwood

plywood

> products but EPA and industry seemingly do not recognize, or want to

> acknowledge, that the other composite wood materials being used in

high-end housing

> today are also a problem. They are going to selectively regulate certain

> composite wood products but not others.

>

> Furthermore, the EPA proposed " emissions rate " is not an

emissions rate at

> all because it is in units of parts per million or billion. PPM is a

> concentration in air, not an emissions rate, and determined by multiple

factors,

> including ventilation. An emissions rate must be in units of mass per

> surface area per time period to be intercomparable between materials. In

> addition, emissions from some materials will continue for much longer time

periods

> than others.

>

> There even is confusion in wording on the EPA website about whether the

> regulations are supposed to address " pressed wood products " or

" composite wood

> products " . Something smells funny to me about these new selective EPA

> regulations and industry's cooperation with EPA on them.

>

> http://www.epa.gov/opptintr/chemtest/formaldehyde/index.html

>

> http://www.epa.gov/sbrefa/formaldehyde.htm

>

> Steve Temes

> AirWays Environmental Services

> Red Bank, NJ

>

[Guest guest]

Jim,

Thanks for you usual excellent points and clarity. Until requirements include the needs of actual human people in real life environments the measurements to determine regulatory compliance will continue to be in terms of the limits of the measuring devices which in a circular way is driven by the regulations. One hazard at a time is insufficient for anything but a lab device measuring one hazard at a time. Show me a real life building or home where the lab approach and set of assumptions is relevant.

The National Center for Healthy Housing is advocating a wholelistic approach which evaluates the integration of the dynamic system which make up a building (not just a home). And, by the way, people are a part of that system.

I anticipate the usual arguments that " this is too complex " and it " isn't affordable " to approach buildings this way. And you are exactly right - from the point of view of one hazard at a time.

But there are other, more common sense, ways of analyzing buildings and the people who occupy them which are still based on and driven by science. We need to shift our thinking and question our assumptions to move forward - which is away from what doesn't sufficiently work.

Carl Grimes

Healthy Habitats LLC

-----

Will

Consultants such as Steve (and myself, now that I am out on my own) do not get paid to measure contaminants but to identify the likely source of problems and the best/cheapest way to solve them.

It is too bad that there was not more funding for decent research on source strengths (your list of questions would be a great start for a good study), but the support for that research evaporated when industry associations convinced all levels of government that industry is the engine of the economy; that is a worse lie than Hitler ever told - we, the consuming public who believe that they can risk buying what the want and need are the engine.

I am all with Steve on the existing standards not measuring source strengths, but only chamber concentrations under optimistic ventilation and loading conditions. The industry says that we (consultants and consumers) could not understand or use source strengths; that is true of most consumers but not of most consultants. Has anyone noticed that suggested residential ventilation rates are set at close to 0.25 AC/h (with the capability of double that) but that chamber rates are set at 0.5? I seldom saw 0.5 AC/h when I was having field tests done and 0.1 was not unusual.

Jim H. White SSC

Re: Panel on Formaldehyde Emissions from Composite Wood Products

Steve:

A few questions:

What neurologic symptoms have you noted in your clients in homes with OSB sheeting?

Are these acute or chronic symptoms?

Have these observed (acute or chronic) symptoms been diagnosed by a physician? If so, what was the VOC involved and what was the exposure concentration?

How were you able to isolate building materials as the source of the VOC issue considering all the other common VOC emitters that consumers introduce into their indoor environment?

On average, what percentage of your clients are suffering neurologic/irritant symptoms?

Thanks for your feedback,

Will

>

> For those concerned about indoor exposures to formaldehyde:

>

> What I have observed in my consulting practice is that new homes

> constructed with OSB sheathing and subflooring, truss joist I-beams (TJIs), and

> microlam girders contain airborne volatile chemicals that cause

> neurologic/irritant symptoms in occupants.

>

> New formaldehyde-emitting particleboard cabinets and subflooring and medium

> density fiberboard (MDF) are materials better known to be problematic.

>

> It seems that new EPA regulations for composite wood products will not even

> address the common composite wood products that are causing problems for my

> clients -- which include OSB, TJIs, and microlams. Industry is interested

> in preventing imports of competing particleboard, MDF, and hardwood plywood

> products but EPA and industry seemingly do not recognize, or want to

> acknowledge, that the other composite wood materials being used in high-end housing

> today are also a problem. They are going to selectively regulate certain

> composite wood products but not others.

>

> Furthermore, the EPA proposed " emissions rate " is not an emissions rate at

> all because it is in units of parts per million or billion. PPM is a

> concentration in air, not an emissions rate, and determined by multiple factors,

> including ventilation. An emissions rate must be in units of mass per

> surface area per time period to be intercomparable between materials. In

> addition, emissions from some materials will continue for much longer time periods

> than others.

>

> There even is confusion in wording on the EPA website about whether the

> regulations are supposed to address " pressed wood products " or " composite wood

> products " . Something smells funny to me about these new selective EPA

> regulations and industry's cooperation with EPA on them.

>

>

http://www.epa.gov/opptintr/chemtest/formaldehyde/index.html

>

>

http://www.epa.gov/sbrefa/formaldehyde.htm

>

> Steve Temes

> AirWays Environmental Services

> Red Bank, NJ

>

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[Guest guest]

Comments:

1. Without measurements and some dose response information one should

not blame the type of product, only suspect it.

2. If I were industry (playing devil's advocate), I might ask: " Why

should I be responsible for your failure to construct a building without

adequate ACH? "

3. Jim - Regarding:

" It is too bad that there was not more funding for decent research on source

strengths "

Some was done a couple decades ago (you know this all too well). It needs

repeating for modern product assemblages.

FYI:

1. I helped a client (manufacturer of wood flooring) complete an

confidential EPA industry survey on wood products and meeting CARB standards

this year. I had been working with my client for 3 years now trying manage

reformulation to reduce HCHO - the isocyanate route has its issues as well.

It appears to me that EPA is gathering data on a) economics of CARB, the

ability to meet capacity requirements, c) the general trend outside of

California, before it weighs in on any true restrictions - smart move for a

change.

2. I suggest getting ahold of:

Gilbert, Air change rate and concentration of formaldehyde in residential

indoor air, Atmos Environ, 42, 2424-2428, 2008

Tony

.......................................................................

" Tony " Havics, CHMM, CIH, PE

pH2, LLC

5250 E US 36, Suite 830 Avon

IN 46123

www.ph2llc.com

off

fax

cell

90% of Risk Management is knowing where to place the decimal point...any

consultant can give you the other 10%(SM)

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[Guest guest]

Will

Consultants such as Steve (and myself, now that I am out on my own) do not get paid to measure contaminants but to identify the likely source of problems and the best/cheapest way to solve them.

It is too bad that there was not more funding for decent research on source strengths (your list of questions would be a great start for a good study), but the support for that research evaporated when industry associations convinced all levels of government that industry is the engine of the economy; that is a worse lie than Hitler ever told - we, the consuming public who believe that they can risk buying what the want and need are the engine.

I am all with Steve on the existing standards not measuring source strengths, but only chamber concentrations under optimistic ventilation and loading conditions. The industry says that we (consultants and consumers) could not understand or use source strengths; that is true of most consumers but not of most consultants. Has anyone noticed that suggested residential ventilation rates are set at close to 0.25 AC/h (with the capability of double that) but that chamber rates are set at 0.5? I seldom saw 0.5 AC/h when I was having field tests done and 0.1 was not unusual.

Jim H. White SSC

Re: Panel on Formaldehyde Emissions from Composite Wood Products

Steve:A few questions:What neurologic symptoms have you noted in your clients in homes with OSB sheeting?Are these acute or chronic symptoms?Have these observed (acute or chronic) symptoms been diagnosed by a physician? If so, what was the VOC involved and what was the exposure concentration?How were you able to isolate building materials as the source of the VOC issue considering all the other common VOC emitters that consumers introduce into their indoor environment?On average, what percentage of your clients are suffering neurologic/irritant symptoms?Thanks for your feedback,Will>> For those concerned about indoor exposures to formaldehyde:> > What I have observed in my consulting practice is that new homes > constructed with OSB sheathing and subflooring, truss joist I-beams (TJIs), and > microlam girders contain airborne volatile chemicals that cause > neurologic/irritant symptoms in occupants.> > New formaldehyde-emitting particleboard cabinets and subflooring and medium > density fiberboard (MDF) are materials better known to be problematic.> > It seems that new EPA regulations for composite wood products will not even > address the common composite wood products that are causing problems for my > clients -- which include OSB, TJIs, and microlams. Industry is interested > in preventing imports of competing particleboard, MDF, and hardwood plywood > products but EPA and industry seemingly do not recognize, or want to > acknowledge, that the other composite wood materials being used in high-end housing > today are also a problem. They are going to selectively regulate certain > composite wood products but not others.> > Furthermore, the EPA proposed "emissions rate" is not an emissions rate at > all because it is in units of parts per million or billion. PPM is a > concentration in air, not an emissions rate, and determined by multiple factors, > including ventilation. An emissions rate must be in units of mass per > surface area per time period to be intercomparable between materials. In > addition, emissions from some materials will continue for much longer time periods > than others.> > There even is confusion in wording on the EPA website about whether the > regulations are supposed to address "pressed wood products" or "composite wood > products". Something smells funny to me about these new selective EPA > regulations and industry's cooperation with EPA on them.> > http://www.epa.gov/opptintr/chemtest/formaldehyde/index.html> > http://www.epa.gov/sbrefa/formaldehyde.htm> > Steve Temes> AirWays Environmental Services> Red Bank, NJ>

[Guest guest]

So if I understand correctly, your response to VOC or other indoor pollutants

(except mold) is to increase ventilation and make an attempt at source control.

Of course source control for formaldehyde is impossible when virtually every

building surface in a residential structure contains UF and the occupant is

creating other sources of formaldehyde on a daily basis.

The ventilation response has been around since AC was first introduced. In the

past, if building occupants complain about odors, simply open the fresh air

dampers and problem fixed - once upon a time electricity was also very

inexpensive. The problem is more challenging today in the commercial ventilation

world.

So if you have a potential residential VOC issue, you simply throw ventilation

at the complaint and hope that dilution solves the problem. If that's the case,

ASHRAE 62.2 ventilation specifications should solve every VOC problem. That's a

$300 per ERV per 3,000 sq/ft solution.

Seems pretty simple and cost effective.

Will

> >

> > For those concerned about indoor exposures to formaldehyde:

> >

> > What I have observed in my consulting practice is that new homes

> > constructed with OSB sheathing and subflooring, truss joist I-beams (TJIs),

and

> > microlam girders contain airborne volatile chemicals that cause

> > neurologic/irritant symptoms in occupants.

> >

> > New formaldehyde-emitting particleboard cabinets and subflooring and medium

> > density fiberboard (MDF) are materials better known to be problematic.

> >

> > It seems that new EPA regulations for composite wood products will not even

> > address the common composite wood products that are causing problems for my

> > clients -- which include OSB, TJIs, and microlams. Industry is interested

> > in preventing imports of competing particleboard, MDF, and hardwood plywood

> > products but EPA and industry seemingly do not recognize, or want to

> > acknowledge, that the other composite wood materials being used in high-end

housing

> > today are also a problem. They are going to selectively regulate certain

> > composite wood products but not others.

> >

> > Furthermore, the EPA proposed " emissions rate " is not an emissions rate at

> > all because it is in units of parts per million or billion. PPM is a

> > concentration in air, not an emissions rate, and determined by multiple

factors,

> > including ventilation. An emissions rate must be in units of mass per

> > surface area per time period to be intercomparable between materials. In

> > addition, emissions from some materials will continue for much longer time

periods

> > than others.

> >

> > There even is confusion in wording on the EPA website about whether the

> > regulations are supposed to address " pressed wood products " or " composite

wood

> > products " . Something smells funny to me about these new selective EPA

> > regulations and industry's cooperation with EPA on them.

> >

> > http://www.epa.gov/opptintr/chemtest/formaldehyde/index.html

> >

> > http://www.epa.gov/sbrefa/formaldehyde.htm

> >

> > Steve Temes

> > AirWays Environmental Services

> > Red Bank, NJ

> >

>

>

>

>

>

> The following section of this message contains a file attachment

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