Officer'sLog: FEMA Trailers and Formaldehyde Hazards
First: Read this short KC Star article:http://www.cdc.gov/niosh/npg/npgd0293.html
Second: My response: I am thinking about sending this in, please read it a give me your opinion on how to improve it (I especially want to hear from peneli and odanu since they seem to have much better writing skills than I) any feedback is good:
I am a retired Navy and Federal Industrial Hygiene Officer who has won the highest professional awards in my field in BOTH federal agencies I worked for (The Brown Award and the VA Secretary's Commendation). I also used to be a member of the KC Federal Executive Board, advising on Safety, Health, Emergency Management and Environmental issues). I think it would be helpful to give you some information that could put the Formaldehyde issues into a framed picture so to speak:
Especially in manufactured homes, there is extensive use of thermoform /thermoset materials used (a liquid first, then sets hard): structural plastics, Wire covering/insulation, PVC plumbing, many glues, many caulks, vinyl compositions, veneers, engineered wood, many composites such as fiberglass, gaskets, and seat foam/foamed in insulation, carpets & carpet pads, kitchen laminate floors, etc. All of these materials use formaldehyde in the mix, and will off-gas formaldehyde, especially at warmer temperatures, under friction/stress, and lower altitudes. Lack of fresh air dilution measured in Room Changes per Hour concentrates exposure levels.
There are two sets of exposure standards: The first it the EPA indoor air quality standards, EPA standards assume a lifetime fatality rate of the general public of 1 per Million, with continuous 24/7 exposure. The EPA standards for its own buildings is its most stringent formaldehyde standard, not to exceed 0.016ppm , see: http://www.epa.gov/rtp/new-bldg/environmental/s_01445.htm
The second is the NIOSH/OSHA occupational standards. These standards assume a worklife exposure of 30 years, 2000 hours a year with a fatality rate of workers 1 per Thousand of occupational populations only. The OSHA (legally enforceable and big business politics are involved) allowed exposures are much higher than the NIOSH standards (recommended and proposed for legal adoption based on occupational research). Both NIOSH and OSHA have the same 8 hour Time Weighted Average (TWA) formula for calculating workday long exposures. OSHA calls them PELs (Permissible Exposure Limit), NIOSH calls them RELs (Recommended Exposure Limit). There is a extraordinary gap between them. For example the NIOSH 8 hr TWA standard is 0.016ppm, the OSHA standard is almost 5000% higher at 0.75ppm. NIOSH and OSHA have the same 15min. TWA formula for calculating Short Term (ST) exposures, again there a difference of magnitudes between enforceable OSHA and evidence based NIOSH standards, in this case 2000%. The NIOSH ST is 0.1ppm, OSHA 2.0ppm, see NIOSH Pocket Guide to Chemical Hazards (2007): http://www.cdc.gov/niosh/npg/npgd0293.html
NIOSH also sets the "golden" standards for recommended respiratory protection: For long term (8 hour) exposures averaging at or greater than 0.016ppm, or ANY detectable exposure (short term sampling methods are less sensitive and have a detection limit of about 0.1ppm) the NIOSH standard is level one protection consisting of a Self Contained Breathing Apparatus (SCBA), the same unit you may have seen used by HazMat and BioHazard teams. A positive pressure airline with full faced mask is also permitted but the user must have SCBA backup anyway. In case of sudden release in normally "safe" (
Second: My response: I am thinking about sending this in, please read it a give me your opinion on how to improve it (I especially want to hear from peneli and odanu since they seem to have much better writing skills than I) any feedback is good:
I am a retired Navy and Federal Industrial Hygiene Officer who has won the highest professional awards in my field in BOTH federal agencies I worked for (The Brown Award and the VA Secretary's Commendation). I also used to be a member of the KC Federal Executive Board, advising on Safety, Health, Emergency Management and Environmental issues). I think it would be helpful to give you some information that could put the Formaldehyde issues into a framed picture so to speak:
Especially in manufactured homes, there is extensive use of thermoform /thermoset materials used (a liquid first, then sets hard): structural plastics, Wire covering/insulation, PVC plumbing, many glues, many caulks, vinyl compositions, veneers, engineered wood, many composites such as fiberglass, gaskets, and seat foam/foamed in insulation, carpets & carpet pads, kitchen laminate floors, etc. All of these materials use formaldehyde in the mix, and will off-gas formaldehyde, especially at warmer temperatures, under friction/stress, and lower altitudes. Lack of fresh air dilution measured in Room Changes per Hour concentrates exposure levels.
There are two sets of exposure standards: The first it the EPA indoor air quality standards, EPA standards assume a lifetime fatality rate of the general public of 1 per Million, with continuous 24/7 exposure. The EPA standards for its own buildings is its most stringent formaldehyde standard, not to exceed 0.016ppm , see: http://www.epa.gov/rtp/new-bldg/environmental/s_01445.htm
The second is the NIOSH/OSHA occupational standards. These standards assume a worklife exposure of 30 years, 2000 hours a year with a fatality rate of workers 1 per Thousand of occupational populations only. The OSHA (legally enforceable and big business politics are involved) allowed exposures are much higher than the NIOSH standards (recommended and proposed for legal adoption based on occupational research). Both NIOSH and OSHA have the same 8 hour Time Weighted Average (TWA) formula for calculating workday long exposures. OSHA calls them PELs (Permissible Exposure Limit), NIOSH calls them RELs (Recommended Exposure Limit). There is a extraordinary gap between them. For example the NIOSH 8 hr TWA standard is 0.016ppm, the OSHA standard is almost 5000% higher at 0.75ppm. NIOSH and OSHA have the same 15min. TWA formula for calculating Short Term (ST) exposures, again there a difference of magnitudes between enforceable OSHA and evidence based NIOSH standards, in this case 2000%. The NIOSH ST is 0.1ppm, OSHA 2.0ppm, see NIOSH Pocket Guide to Chemical Hazards (2007): http://www.cdc.gov/niosh/npg/npgd0293.html
NIOSH also sets the "golden" standards for recommended respiratory protection: For long term (8 hour) exposures averaging at or greater than 0.016ppm, or ANY detectable exposure (short term sampling methods are less sensitive and have a detection limit of about 0.1ppm) the NIOSH standard is level one protection consisting of a Self Contained Breathing Apparatus (SCBA), the same unit you may have seen used by HazMat and BioHazard teams. A positive pressure airline with full faced mask is also permitted but the user must have SCBA backup anyway. In case of sudden release in normally "safe" (