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Formaldehyde; TSCA Review

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American Industrial Hygiene Association (AIHA) filings
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American Industrial Hygiene Association (AIHA) filed 1 comment on this docket between Feb 3, 2026 and Feb 3, 2026. 64 other organizations filed here. The comment window closed 176d ago.

What American Industrial Hygiene Association (AIHA) filed (1)

Feb 3, 2026· Comment submitted by American Industrial Hygiene Association (AIHA)· EPA-HQ-OPPT-2018-0438-0428

The American Industrial Hygiene Association, AIHA, is an association for scientists and professionals committed to preserving and ensuring occupational and environmental health and safety. We appreciate the opportunity to provide feedback on EPA's updated draft risk calculation and other related documents for formaldehyde under TSCA. We hope you find our feedback useful and are happy to answer any questions you may have. 1.AIHA Encourages EPA to Consider Workplace Variability in the Data Received/Reviewed AIHA encourages EPA to consider that the data they are reviewing in the risk evaluation phase, takes into account various exposure controls in place in the workplace. It may not be appropriate to assume every workplace is OSHA compliant, as the degree of compliance across industry and within sectors is a continuum. The variability in the data may reflect different workplace scenarios and exposure controls in place. EPA is encouraged to fully understand the holistic nature of the data in the risk evaluation phase better, and contextualize the data to help inform the results in the risk evaluation. EPA can leverage AIHA's knowledge about the range of typical IH practices associated with the data collection. This information will better support the conclusion in the risk management phase. 2.AIHA's Recommendations Regarding EPA's Dermal Exposure Approach EPA used a screening level approach to dermal exposure assessment that resulted in conclusions of unreasonable risk of injury to workers based on those exposures. AIHA recommends that EPA incorporate higher tier dermal exposure assessment techniques in its risk evaluations. AIHA has several resources that provide guidance on estimating dermal exposures. AIHA's "Mathematical Models for Estimating Occupational Exposure to Chemicals, 2nd Edition" specifically addresses dermal exposure modeling. It notes "[t]he U.S. EPA in the Risk Assessment Guidance for Superfund (RAGS) Supplemental Guidance for Dermal Risk Assessment...describes a dermal exposure estimation model in which the absorbed dose can be derived using either a permeability coefficient (for aqueous solutions) or a fraction of absorbed dose (for non-aqueous and non-steady state conditions such as exposure to soil" (Keil et al. 2009). In prior risk evaluations, a fractional absorption approach was used more frequently by EPA for estimation of dermal exposure. However, with regards to the fractional absorption approach, Frasch et al. (2014) identified several potential limitations that should be considered when applying a fractional absorption approach (effects of loading, effects of evaporation, duration of experimentation to derive percent absorbed, and consideration of absorption that may occur following the exposure time). Lynch et al. (2023) compared results of the fractional absorption modeling approach to a flux-based approach for three chlorinated organic chemicals with high rates of volatilization and found 2- to 20-fold higher estimates of exposure with the fractional absorption approach. The AIHA dermal absorption model IH SkinPerm uses a permeability coefficient approach (Tibaldi et al. 2014). IH SkinPerm is designed for three types of occupational skin exposures found in work environments. The assessment scenarios include instantaneous depositions, such as from a splash; deposition over time, such as from repeated or continuous emission; and skin absorption from airborne vapors. 3.AIHA Supports the General Approach that Sensory Irritation (as an Endpoint) is Protective for Chronic Exposures AIHA, in general, supports EPA's application of the recommendations of federal advisory committees in using sensory irritation as an endpoint that is protective of chronic exposures. Sensory irritation is a sensitive and relevant end point in human risk assessment, for many chemicals. By one estimate, 40 % of the occupational exposure limit values (OELs) are based on the avoidance of sensory irritation (Brüning…

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Abstract

EPA is interested in information on Formaldehyde (CASRN 50-00-0). EPA encourages the public to submit use, hazard, and exposure information to this docket.

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