TSCA risk evaluation-directed characterization of occupational exposures during formaldehyde manufacturing, use as an intermediate, and compounding of formaldehyde-based polymers

Abstract

In 2020, the U.S. EPA initiated TSCA risk evaluations for 20 High Priority chemicals, as required by the Lautenberg Act. In addition to consumer exposures, the evaluations include quantitative assessments of worker exposures, hazards and risk. The EPA evaluations of worker exposures, and authority over corrective action to address unacceptably high workplace exposures, overlap OSHA's authority for regulating workplace exposures. This dual federal regulatory authority for risk evaluation and risk management, presents new challenges for industrial hygienists, exposure/risk assessors, and risk managers. One of the chemicals identified as High Priority by the EPA is formaldehyde. In response to these challenges, Celanese supplemented its regular OSHA compliance sampling for formaldehyde with a one-time comprehensive sampling at our sole U.S. formaldehyde manufacturing facility. The sampling characterized all worker populations at the facility, including office workers. Although the EPA assessment is ongoing and may reach different conclusions related to an acceptable exposure limit, 126 full-shift monitoring results demonstrated compliance with the OSHA Formaldehyde Standard (29 CRF 1910.1048) for health protection. Methodologies used to identify workers for exposure monitoring, to characterize multiple EPA-specified worker populations, as well as potential challenges related to the dual regulatory authority for assessing and managing worker exposures are discussed.