Environmental Engineering Reference
In-Depth Information
uation and Control of LBP Hazards in Housing in 1995
. These guidelines are
good practice documents that describe inspection, risk assessment, and
abatement practices. Though not rules, they are, for all practical purposes,
standards of care by which professional activities associated with LBP haz-
ards are to be conducted.
C. Formaldehyde
Regulatory involvement in the problem of HCHO-related odor and health
complaints began in the late 1970s. These complaints were reported for UFFI
houses, mobile homes, and stick-built homes using UF-bonded wood prod-
ucts. Complaints were directed to state and local health, consumer, and
environmental agencies, and, at the federal level, to CPSC. Health authorities
in many states conducted investigations of complaints and provided HCHO
air testing services. As a result of such investigations, public health depart-
ments in several states instituted efforts to control one or more aspects of
the “formaldehyde problem” through regulatory initiatives.
In 1980, Massachusetts banned the sale and installation of UFFI in resi-
dential structures and required installers, distributors, or manufacturers to
repurchase the product at homeowner request. Though initially overturned
on appeal, the ban was sustained by the Massachusetts Supreme Court and
remains in effect. A ban on UFFI for residential applications also went into
effect in Connecticut.
The Minnesota state legislature enacted an HCHO statute in 1980 autho-
rizing the Health Commissioner to promulgate rules regulating the sale of
building materials and housing units constructed with UF-containing mate-
rials. The Minnesota law required written disclosure prior to the sale of new
homes and construction materials containing UF resins. After an attempt to
establish a 0.1 ppmv IAQ standard for new homes was unsuccessful, the
Minnesota Health Commissioner adopted an IAQ standard of 0.5 ppmv for
new housing units and UFFI installations. The standard was appealed and
upheld by the Minnesota Supreme Court, which remanded the 0.5 ppmv
level back to the state health department for reconsideration. Subsequently,
an IAQ standard of 0.4 ppmv was adopted and went into effect in 1985.
Because of preemption by HUD rules (see below), the Minnesota HCHO
statute was amended to establish product standards; the IAQ standard was
then repealed. In the early 1980s, Wisconsin promulgated an IAQ standard
for new mobile homes. Because of legal and political problems, the standard
was never enforced.
In response to numerous complaints associated with UFFI installations
and its own investigations of the problem, CPSC proposed rules in 1980 that
would have required UFFI installers, distributors, and manufacturers to
notify prospective purchasers of the potential adverse effects associated with
the product. It subsequently concluded that such disclosure would not ade-
quately protect the public and, as a result, imposed a ban on UFFI in 1982.
In promulgating the ban, CPSC denied a petition by the Formaldehyde
