NFDA Special Advocacy Bulletin: EPA Set to Release Formaldehyde Draft Risk Assessment Tomorrow
The day funeral service has been waiting for since 2019 is almost here. NFDA has learned that tomorrow, March 15, the U.S. Environmental Protection Agency (EPA) will release its draft risk assessment of formaldehyde.
The EPA selected formaldehyde for a risk assessment under the Toxic Substances Control Act (TSCA) in 2019. TSCA requires the EPA to periodically conduct risk assessments to determine whether particular uses of various chemicals present an unreasonable risk to human health or the environment.
This draft risk assessment will indicate whether formaldehyde poses an unreasonable risk to human health or the environment and at what level. Following the publication of the draft risk assessment in the Federal Register, there will be a 60-day public comment period. The EPA will then take comments under advisement and finalize the risk assessment. We will be asking funeral service professionals to provide comments to the EPA about the impact of their decisions on funeral service. This is a time where the profession needs to speak with one loud, unified voice!
If the final EPA risk assessment finds that formaldehyde presents an unreasonable risk to human health or the environment, it could result in the agency taking actions, such as:
- Establishing very low exposure standards
- Enacting management restrictions
- Setting standards that funeral directors and embalmers must meet to embalm with formaldehyde and issuing violation notices and penalties should they not comply
- Strict exposure controls and exposure limits for remaining permissible industrial or commercial uses, with strict recordkeeping requirements
- Phase out periods for restricted uses ranging from 180 days to 10 years, depending on the product
- Prohibition of consumer uses
- Prohibition of most industrial and commercial uses
NFDA will share more information in a Special Bulletin as soon as we have had time to analyze the draft risk assessment.
NFDA will also host a free webinar for members at 10 a.m. CT on Wednesday, March 27. NFDA Senior Vice President, Advocacy, Lesley Witter, will share vital information about what the draft risk assessment may mean for you and next steps in the TSCA process. Be among the first to learn more and register for The Number Is In! An Update on the EPA Formaldehyde Review and the NEW Proposed Formaldehyde Exposure Limit.
NFDA Takes the Lead for the Profession
From the moment the EPA selected formaldehyde for review in 2019, NFDA has been the leading voice for funeral service.
NFDA provided multiple rounds of oral and written testimony to the EPA. NFDA has also educated Congress and the EPA about the importance of formaldehyde in the embalming process and the right of Americans to hold an open casket funeral.
Additionally, NFDA commissioned the peer-reviewed and published NFDA Formaldehyde Exposure Study to offer current data that characterizes expected formaldehyde exposure in the 21st Century.
NFDA’s scientific study found that the level of exposure to formaldehyde for funeral directors and embalmers during an embalming is less than current Occupational Safety and Health Administration permissible eight-hour and short-term exposure limits. NFDA’s data shows that trained funeral service professionals can effectively manage their exposure to formaldehyde to well-below current occupational limits – information that has been shared with the EPA in both oral and written testimony.
The results of this study were published in the peer-reviewed scientific Journal of Occupational and Environmental Hygiene, lending weight and credibility to the findings and presenting a stark contrast to existing scientific data.
This EPA risk assessment is a multi-phase process that is expected to last until at least 2026, likely longer. NFDA will keep you informed as it continues to engage on your behalf and that of the profession.
