By Leader Editor Kara Apel
The NFDA has submitted comments to the EPA regarding the agency’s ongoing formaldehyde risk assessment, which is being conducted as part of the Toxic Substances Control Act.
Passed in 1976, the Toxic Substances Control Act grants the EPA the authority to require reporting, record-keeping and testing requirements, and restrictions relating to chemical substances and/or mixtures.
If the EPA’s assessment of formaldehyde determines that the chemical presents an unreasonable risk to human health or the environment, it is possible that controls or restrictions could be imposed on its use, which would have a direct impact on the funeral profession.
The multi-phase assessment is expected to take until 2025 to complete.
NFDA wrote this in an email to its members earlier this month:
“As it conducts its risk assessment, the EPA will be using available scientific data. Unfortunately, the funeral profession lacks recent, reliable scientific data related to the use of formaldehyde in embalming. Available studies were mostly conducted prior to the 1980s and do not represent accurate embalming practices today. To show that funeral service professionals understand how to safely use formaldehyde, we wanted to provide the EPA with more current data that characterizes the typical preparation room in 2021. NFDA hired a scientific consulting firm to conduct an exposure study on the use of formaldehyde in embalming, something that hasn’t been done in almost four decades. This scientific consulting firm is recognized worldwide for its technical capabilities and experience working with the EPA on chemical risk assessments.”
NFDA noted the results of the study contain data from 13 different funeral homes of different ages across the country, representing different numbers of annual embalming cases, to “include a range of exposure scenarios for workers in the profession.”
The study was open to all funeral service professionals and was not just confined to NFDA members.
The association says the results from the study proves that the mean task-exposure concentration of formaldehyde during an active embalming was 0.68 ppm. This is less than the current permissible exposure limits, including the eight-hour exposure limit of 0.75 and the short-term exposure limit of 2 ppm.
The NFDA said this in its comments: “Though the use of formaldehyde has not substantively changed, nor has the formaldehyde content of products used in embalming, the Study shows exposures to formaldehyde during active embalming are lower than are typically reported in the outdated published literature, particularly with respect to upper-bound exposure concentrations. “
Click here to read the full letter from the NFDA to the EPA.
