The Biden administration finalized
a risk evaluation for formaldehyde just before Trump took office. Now, the
Trump EPA has updated that risk evaluation. The result is that allowable
workplace levels are not likely to be lowered.
Formaldehyde is released
naturally from the breakdown of organic materials like wood chips and leaves.
It is also used in the manufacture of plastics, resins, textiles, cosmetics,
foam bedding/seating, semiconductors, glues, composite wood products, paints,
coatings, rubber, construction materials (including roofing), furniture, toys,
and various adhesives and sealants. It is also present in car exhaust and other
combustion sources. Formaldehyde exposure has been linked to increased cancer
risk, miscarriages, and respiratory issues. Exposure pathways include
inhalation, skin absorption, and eating and drinking, since some fruits contain
it.
The risk evaluation concerns
formaldehyde’s use in manufacturing and related workplace exposure. The
chemical industry opposed the Biden administration’s plans to reduce workplace
exposure, but the Trump administration is likely to ignore those
recommendations.
The Environmental Defense
Fund’s chemicals policy director, Maria Doa, complained that the Trump
administration cherry-picked data to arrive at conclusions not supported by the
data and that chemical industry lobbyists were now leading the EPA. Some have
worked for the American Chemistry Council, which opposes many regulations, and
some worked directly on opposing new proposed allowable levels for
formaldehyde. At issue are things like requiring respirators to be worn where
exposure risk is high.
The Biden EPA risk evaluation
was conducted under the Toxic Substances Control Act (TSCA) and determined
that:
“…formaldehyde presents an unreasonable risk of injury
to human health, specifically to workers and consumers, under its conditions of
use (COUs).”
Formaldehyde does break down in the
environment. Thus, it is not considered an environmental threat. Chronic and
acute workplace exposures are probably the highest risk factors. According to
the Biden EPA’s risk evaluation:
“Workers who are in workplaces where formaldehyde is
used are at the most risk from formaldehyde exposure, particularly if workers
are not wearing personal protective equipment. Workers may be exposed to
formaldehyde in air during manufacturing, processing, or use of formaldehyde
and products and articles containing formaldehyde. Workers can also be exposed
to formaldehyde by making skin contact with formaldehyde-containing materials.
Most of the risk to workers is because of acute inhalation and dermal exposures.
Cancer risk to workers under many conditions of use also supports the risk
determination.”
The Obama administration
signed the bipartisan Lautenberg Act in 2016 to update the TSCA, but now it
appears some of it could be rolled back.
According to the updated
Trump EPA risk evaluation, the draft version, published in December 2025, it:
“…provides risk estimates from acute inhalation
exposures based on feedback from independent peer reviewers, enhancing the
scientific rigor of the underlying information used to support the risk
determination while maintaining EPA’s January 2025 determination that
formaldehyde presents an unreasonable risk of injury to human health,
specifically to workers and consumers, under its conditions of use. The Agency
will simultaneously continue working on a proposed risk management rule for
formaldehyde as required by TSCA. EPA plans to expeditiously convene a Small
Business Advocacy Review Panel to get input on a proposed rule. The agency will
rely on gold standard science and take the Updated Draft Risk Calculations and
Revised Draft Risk Evaluation into account when drafting a proposed risk
management rule to meet statutory deadlines and ensure health protections.”
“Consistent with statutory obligations and Executive
Order (EO) 14303, Restoring Gold Standard Science, EPA is committed to the
highest standards of scientific integrity and reliance on the best available
scientific information. As such, OCSPP has re-evaluated the use of the IRIS
cancer IUR in the formaldehyde risk evaluation. EPA has considered the
peer-review record, including comments from the Science Advisory Committee on
Chemicals (SACC), the Human Studies Review Board (HSRB), and National Academies
of Sciences, Engineering, and Medicine. Following their recommendations and
focusing on the science, EPA is issuing this Updated Draft Risk Calculation
Memorandum which was used as the basis for the Revised Draft Risk Evaluation
for Formaldehyde.”
“Consistent with the recommendations from the SACC, EPA
is supplementing the endpoints used in the TSCA risk evaluation to determine
human health effects from formaldehyde. In its review of the draft formaldehyde
risk evaluation, the SACC was generally critical of the agency’s reliance on
cancer and non-cancer hazard values for formaldehyde inhalation presented in
the draft IRIS Toxicological Review of Formaldehyde – Inhalation.”
“In this Updated Draft Risk Calculation Memorandum and
the documents that rely on the information presented in the Updated Draft Risk
Calculation Memorandum, EPA is proposing that the best available science
supports using sensory irritation as the most sensitive endpoint for
determining human health effects from inhalation exposures. Managing risks from
acute sensory irritation will be protective against other health effects,
including cancer. This approach is supported by the recommendations of the SACC
and other federal advisory committees. Because this Updated Draft Risk
Calculation Memorandum implements recommendations from the multiple peer review
bodies, additional peer review is not necessary.”
I am not quite sure what they
mean when they say, “using sensory irritation as the most sensitive endpoint
for determining human health effects from inhalation exposures.” It sounds
like they are focused more on acute exposures and perhaps ignoring chronic
exposures. Evaluating the risks from chronic exposures is no doubt more
difficult, but that does not mean those risks should be ignored. The focus on
acute exposure is supported in the December 2025 EPA memorandum on the subject,
although they do acknowledge that there are risks associated with long-term
exposure.
“Short-term inhalation exposure to high levels of
formaldehyde can cause sensory irritation and respiratory effects. Short-term
skin contact can cause sensitization. Exposure over longer periods can also
cause respiratory effects and cancer. The complex toxicology and exposure
profiles for formaldehyde make its evaluation challenging. The formaldehyde
sources that EPA evaluated in the TSCA risk evaluation, and this Draft
Memorandum, involve, in general, the production and use of products that are
subject to TSCA (as opposed to products that are specifically excluded from
TSCA under 15 U.S.C. 2602(2)(B), such as pesticides).”
Both the Biden and Trump risk
evaluations focus on inhalation as the main exposure pathway. However, the
Trump EPA evaluation does not consider cumulative exposure in its evaluation.
The Biden EPA identified 58 scenarios in which formaldehyde can present an
“unreasonable risk” to human health, and the Trump administration is reversing
five of those.
The bottom line is that
workplace exposure levels that the Biden EPA determined are a cancer risk will
not be considered a cancer risk under the Trump EPA.
References:
EPA
Finalizes TSCA Risk Evaluation for Formaldehyde. U.S. EPA. Released January 2,
2025. EPA Finalizes TSCA Risk Evaluation
for Formaldehyde | US EPA
Officials
spark backlash with plan that could expose Americans to toxic threat:
'Horrendous'. Susan Elizabeth Turek. The Cool Down. February 11, 2026. Officials spark backlash with plan
that could expose Americans to toxic threat: 'Horrendous'
EPA
Releases Updated Draft Risk Calculation Memorandum for Formaldehyde under TSCA
for Public Comment. U.S. EPA. Released December 3, 2025. EPA Releases Updated Draft Risk
Calculation Memorandum for Formaldehyde under TSCA for Public Comment | US EPA
Trump’s
EPA wants to weaken formaldehyde protections – this is what it could mean. Tom
Perkins. The Guardian. December 19, 2025. Trump’s EPA wants to weaken
formaldehyde protections – this is what it could mean | Trump administration |
The Guardian
Our
toxic chemicals safety law is under attack. Environmental Defense Fund. September
8, 2025. Our toxic chemicals safety law is
under attack | Environmental Defense Fund
Formaldehyde;
Updated Draft Risk Calculation Memorandum; Notice of Availability and Request
for Comment. Notice by the Environmental Protection Agency on 12/03/2025.
Federal Register. Federal Register :: Formaldehyde;
Updated Draft Risk Calculation Memorandum; Notice of Availability and Request
for Comment
How
our bedrock chemical safety law, the Lautenberg Act, protects us. Environmental
Defense Council. November 25, 2025. How
our bedrock chemical safety law, the Lautenberg Act, protects us | EDF
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