WASHINGTON (December 20, 2022) — Today, the American Chemistry Council’s (ACC) Formaldehyde Panel (the Panel) issued a statement calling for meaningful opportunities for public comment related to the National Academy of Sciences, Engineering, and Medicine (NASEM) Committee review of EPA's 2022 Draft Formaldehyde Assessment. NASEM has scheduled their second public meeting regarding the formaldehyde assessment for Thursday, December 22, from 3:00pm to 4:00pm ET, and is merely allowing 3 minutes for each commenter. As with concerns raised regarding the first public meeting held on October 12, this second meeting was not designed to solicit meaningful public input.
“The week surrounding the holidays is one of the busiest of the year. Scheduling a public meeting during a time when many already have holiday plans and only allowing 3 minutes per speaker disparages public participation and impedes the committee’s ability to hear about the critical, nuanced scientific developments that must be understood. Public comments should not be a mere box-checking exercise but a meaningful opportunity to exchange scientific information” said Sahar Osman-Sypher on behalf of the Panel.
ACC’s Formaldehyde Panel has previously written NASEM requesting an information gathering session and at least four hours for public comment in order to allow scientists who have been studying formaldehyde science for decades to provide the committee with an in-depth understanding of the literature. These requests continue to be ignored.
The NASEM peer review committee should welcome the opportunity to draw on the vast scientific expertise that exists from stakeholders on formaldehyde. Given the unfortunate timing of Dec 22nd, the NASEM meeting once again highlights the lack of meaningful opportunities for public comment. We respectfully ask that they give this issue proper attention by providing adequate opportunities for meaningful public participation. We renew our request for an information gathering session and urge NASEM to explain why more opportunities are not given for public participation in this important process.
The limited opportunity for public participation in this upcoming meeting are the latest troubling developments in a series of continued and compounding process irregularities for developing and reviewing the U.S. Environmental Protection Agency’s (EPA) 2022 draft formaldehyde Integrated Risk Information System (IRIS) assessment. The panel has already sent the committee a letter articulating some of the scientific flaws with the 2022 draft IRIS assessment. According to several regulatory bodies and scientific agencies, the weight of evidence clearly indicates that formaldehyde poses no risk at environmentally relevant exposure levels. Decades of research, hundreds of published scientific papers, and global agencies including The World Health Organization (WHO) and The European Chemicals Agency have found that there is no association between formaldehyde and leukemia. Groups like the WHO have set realistic, protective air guidelines at or above 80 parts per billion (ppb).
Formaldehyde is one of the most studied chemicals in use today and more than 30 years of advanced science and practical experience clearly indicates there is a safe exposure level. Out of step with many other formaldehyde reviews, the EPA’s draft IRIS assessment suggests a suite of health effects, including cancer and noncancer effects, at levels ranging from well below 1 to 7 ppb. The EPA's decision to ignore updated science that addresses many of the criticisms NASEM raised prompts additional concerns for the 2022 draft IRIS assessment. Assuring transparency, adherence to process, and sound science are particularly important for this draft of the formaldehyde assessment, as the previous (2010) draft was so highly problematic as to be a driver for subsequent reform of the IRIS Program.
