PAGENO="0001" FEDERAL RESPONSE TO HEALTH RISKS OF FORMALDE- HYDE IN HOME INSULATION, MOBILE HOMES, AND OTHER CONSUMER PRODUCTS ~`2cQD2O~'U) HEARINGS BEFORE A SUBCOMMITTEE OF THE COMMITTEE ON GOVERNMENT OPERATIONS HOUSE OF REPRESENTATIVES NINETY-SEVENTH CONGRESS SECOND SESSION MAY 18 AND 19, 1982 Printed for the use of the Committee on Government Operations 0 U.S. GOVERNMENT PRINTING OFFICE 974530 WASHINGTON : 1982 PAGENO="0002" COMMITTEE ON GOVERNMENT OPERATIONS JACK BROOKS, Texas, Chairman L. H. FOUNTAIN, North Carolina FRANK HORTON, New York DANTE B. FASCELL, Florida JOHN N. ERLENBORN, Illinois BENJAMIN S. ROSENTHAL, New York CLARENCE J. BROWN, Ohio DON FUQUA, Florida PAUL N. McCLOSKEY, JR., California JOHN CONYERS, Ja., Michigan THOMAS N. KINDNESS, Ohio CARDISS COLLINS, Illinois ROBERT S. WALKER, Pennsylvania JOHN L. BURTON, California M. CALDWELL BUTLER, Virginia GLENN ENGLISH, Oklahoma LYLE WILLIAMS, Ohio ELLIOTT H. LEVITAS, Georgia JOEL DECKARD, Indiana DAVID W. EVANS, Indiana WILLIAM F. CLINGER, JR., Pennsylvania TOBY MOFFETT, Connecticut RAYMOND J. McGRATH, New York HENRY A. WAXMAN, California HAL DAUB, Nebraska FLOYD J. FITHIAN, Indiana JOHN HILER, Indiana TED WEISS, New York WENDELL BAILEY, Missouri MIKE SYNAR, Oklahoma LAWRENCE J. DENARDIS, Connecticut EUGENE V. ATKINSON, Pennsylvania* JUDD GREGG, New Hampshire STEPHEN L. NEAL, North Carolina MICHAEL G. OXLEY, Ohio DOUG BARNARD, JR., Georgia PETER A. PEYSER, New York BARNEY FRANK, Massachusetts HAROLD WASHINGTON, Illinois TOM LANTOS, California BARBARA B. KENNELLY, Connecticut WILLIAM M. JONES, General Counsel JOHN E. MOORE, Staff Administrator JOHN M. DUNCAN, Minority Staff Director COMMERCE, CONSUMER, AND MONETARY AFFAIRS SUBCOMMIrFEE BENJAMIN S. ROSENTHAL, New York, Chairman JOHN CONYERS, JR., Michigan LYLE WILLIAMS, Ohio EUGENE V. ATKINSON, Pennsylvania HAL DAUB, Nebraska STEPHEN L. NEAL, North Carolina WILLIAM F. CLINGER, Ja., Pennsylvania DOUG BARNARD, JR., Georgia JOHN HILER, Indiana. PETER A. PEYSER, New York BARBARA B. KENNELLY, Connecticut Ex OFFicIo JACK BROOKS, Texas FRANK HORTON, New York PETER S. BARASH, Staff Director THEODORE J. JACOBS, Chief Counsel DONALD P. TUCKER, Chief Economist ANDREW W. SAVITZ, Professional Staff Member (II) PAGENO="0003" CONTENTS Hearings held on- Page May18 May 19 315 Statement of- Abrams, Philip, General Deputy Assistant Secretary for Housing, U.S. Department of Housing and Urban Development, accompanied by Ber- nard Shriber, Executive Assistant to the General Deputy Assistant Secretary for Housing 361 Barth, Marianne, UFFI homeowner, Cotuit, Mass 77 Breysse, Peter, associate professor, Department of Environmental Health, School of Public Health and Community Medicine, University of Wash- ington, Seattle, Wash 276 Ehrle, William L., National Manufactured Housing Federation, Inc 410 Geller, Jeanette, mobile homeowner, Lithia Springs, Ga 87 Griesemer, Dr. Richard A., Director, Biology Division, Oak Ridge Nation- al Laboratory, Oak Ridge, Tenn 266 Higginson, John, M.D., senior scientist, Universities Associated for Re- search and Education in Pathology, Inc 385 Howlett, Clifford T., Jr., vice chairman, Formaldehyde Institute 399 LaFalce Hon. John J., a Representative in Congress from the State of New York 2 Lovejoy, John and Cathy, mobile homeowners, Cross Lanes, W. Va., ac- companied by Ian Lovejoy 136 McArdle, Brian P., project leader, Biospherics, Inc 373 Newhouse, Michael, M.D., clinical professor of medicine, McMaster Uni- versity, Hamilton, Ontario, Canada 377 Prisand, Dr. Gary M., UFFI homeowner, New Jersey 83 Rosenthal, Hon. Benjamin S., a Representative in Congress from the State of New York, and chairman, Commerce, Consumer, and Mone- tary Affairs Subcommittee: Opening statement 1 Smrecek, Connie, national coordinator, SUFFER, accompanied by Marc Kurzman, consulting attorney 5 Sloan, Edith Barksdale, Commissioner, U.S. Consumer Product Safety Commission 332 Statler, Stuart M., Commissioner, U.S. Consumer Product Safety Commis- sion 334 Steorts, Nancy Harvey, Chairperson, U.S. Consumer Product Safety Com- mission 315 Swanick, Charles, assemblyman, New York Legislature, representing Erie County 143 Valdes-Dapena, Marie, M.D., professor of pediatrics and pathology, Uni- versity of Miami School of Medicine 392 Westgate, Hugh D., M.D., anesthesiologist, Children's Health Center, Minneapolis, Minn 228 Zagoria, Sam, Commissioner, U.S. Consumer Product Safety Commission.. 337 Letters, statements, etc., submitted for the record by- Barth, Marianne, UFFI homeowner, Cotuit, Mass.: Correspondence rela- tive to the hearings 81-82 Breysse, Peter, associate professor, Department of Environmental Health, School of Public Health and Community Medicine, University of Wash- ington, Seattle, Wash.: Prepared statement 280-306 Ehrle, William L., National Manufactured Housing Federation, Inc.: June 17, 1982, letter to Chairman Rosenthal concerning Fleetwood Enterprises, Inc 443 Prepared statement 412-432 (III) PAGENO="0004" Iv Letters statements, etc., submitted for the record by-Continued Geller, Jeanette, mobile homeowner, Lithia Springs, Ga.: Prepared state- Page ment 92-135 Griesemer, Dr. Richard A., Director, Biology Division, Oak Ridge Nation. al Laboratory, Oak Ridge, Tenn.: Prepared statement 269-276 Higginson, John, M.D., senior scientist, Universities Associated for Re- search and Education in Pathology, Inc.: Prepared statement 389-392 Howlett, Clifford T., Jr., vice chairman, Formaldehyde Institute: Attach- ments to prepared statement 406-409 Lovejoy, John and Cathy, mobile homeowners, Cross Lanes, W. Va.: Pre- pared statement 140-142 McArdle, Brian P., project leader, Biospherics, Inc.: May 19, 1982, letter to subcommittee reporting airborne formaldehyde samples found in a 70- by 14-foot Fiesta trailer 374 Newhouse, Michael, M.D., clinical professor of medicine, McMaster Uni- versity, Hamilton, Ontario, Canada: Attachments to prepared state- ment 383-385 Prisand, Dr. Gary M., UFFI homeowner, New Jersey: List of studies 86 Rosenthal, Hon. Benjamin S., a Representative in Congress from the State of New York, and chairman, Commerce, Consumer, and Mone- tary Affairs Subcommittee: May 12, 1982, letter from Commissioner Statler concerning his views on urea formaldehyde foam insulation .... 335-336 Shriber, Bernard, Executive Assistant to the General Deputy Assistant Secretary for Housing, U.S. Department of Housing and Urban Devel- opment: Health studies reviewed by HUD 366 Smrecek, Connie, national coordinator, SUFFER: Prepared statement 11-76 Steorts, Nancy Harvey, Chairperson, U.S. Consumer Product Safety Com- mission: April 29, 1982, letter from Chairman Rosenthal concerning May 19, 1982, hearings on urea formaldehyde foam insulation and other formaldehyde products 316-317 Canadian consumer assistance program for UF foam insulation homeowners 343-354 Estimates of residential installations of UF foam insulation 319 Information concerning the ban of UFFI 359 Manufacturers of UF foam resins 341 Questions and answers on urea-formaldehyde foam insulation 324-330 Swanick, Charles, assemblyman, New York Legislature, representing Erie County: Prepared statement 155-227 Westgate, Hugh D., M.D., anesthesiologist, Children's Health Center, Minneapolis, Minn.: Prepared statement 234-265 APPENDIX Correspondence and material submitted for the hearings 445 PAGENO="0005" FEDERAL RESPONSE TO HEALTH RISKS OF FORMALDEHYDE IN HOME INSULATION, MOBILE HOMES, AND OTHER CONSUMER PRODUCTS TUESDAY, MAY 18, 1982 HOUSE OF REPRESENTATIVES, COMMERCE, CONSUMER, AND MONETARY AFFAIRS SUBCOMMITTEE OF THE COMMITTEE ON GOVERNMENT OPERATIONS, Washington, D.C. The subcommittee met, pursuant to notice, at 10:05 a.m., in room 2154, Rayburn House Office Building, Hon. Benjamin S. Rosenthal (chairman of the subcommittee) presiding. Present: Representatives Benjamin S. Rosenthal, Doug Barnard, Jr., Hal Daub, William F. Clinger, Jr., and John Hiler. Also present: Peter S. Barash, staff director; Andrew W. Savitz, professional staff member; Eleanor M. Vanyo, secretary; and Jack Shaw, minority professional staff, Committee on Government Oper- atiOns. OPENING STATEMENT OF CHAIRMAN ROSENTHAL Mr. ROSENTHAL. The subcommittee will be in order. Today and tomorrow the Commerce, Consumer, and Monetary Affairs Subcommittee will examine the Federal response to reports of formaldehyde-related health problems from products utilized by America's consumers. The hearing will focus on the health effects and economic conse- quences of formaldehyde in two products-home insulation and mobile homes. On February 22, 1982, the Consumer Product Safety Commission banned the use of urea formaldehyde foam as an insulator in the walls of homes and schools. The Commission has primary Federal responsibility for 2stablishing product safety standards and for ban- ning hazardous consumer products. The subcommittee seeks to determine the Federal role in approv- ing formaldehyde foam as a home insulator, the adequacy and impact of the Product Safety Commission ban, and whether or not further Federal assistance is justified for the 500,000 homeowners who had formaldehyde foam installed prior to the ban. We will also be examining the nature and extent of health prob- lems caused by the release of formaldehyde gas from products used (1) PAGENO="0006" 2 extensively in the construction of mobile homes-plywood, particle board, and other pressed wood products. The subcommittee wants to know whether the Department of Housing and Urban Development, which has responsibility for es- tablishing mobile home safety, construction, and performance standards, is dealing effectively with the formaldehyde health issue. Approximately 250,000 mobile homes are sold and manufactured in the United States each year. Mobile homes constituted 36 per- cent of the new single-family homes sold in 1981. This morning the subcommittee will hear testimony from con- sumers who have been exposed to formaldehyde products. Some have had urea formaldehyde foam insulation installed in their homes. Others have been living in mobile homes. We will also be hearing today from scientists and physicians who have studied the formaldehyde problem or who have treated per- sons exposed to formaldehyde gas. Tomorrow, witnesses from the Consumer Product Safety Commis- sion and the Department of Housing and Urban Development will describe the Federal response to the formaldehyde issue. Witnesses from the Formaldehyde Institute, the National Manu- factured Housing Federation, and others will also testify. Our first witness this morning is Congressman John J. LaFalce who has just arrived from Buffalo. We are delighted he is with us. We will hear from Mr. Swanick after Mr. LaFalce has completed his testimony. Mr. LaFalce, welcome. You may proceed. STATEMENT OF HON. JOHN J. LAFALCE, A REPRESENTATIVE IN CONGRESS FROM THE STATE OF NEW YORK Mr. LAFALCE. Thank you, Mr. Chairman. I am pleased to have the opportunity to testify before this sub- committee on the urea formaldehyde foam insulation, UFFI, issue. May I begin by saying that I appreciate the initiative being taken by this subcommittee and I also appreciate the complexity of the task which confronts you. The Consumer Product Safety Commission, CPSC, under the leadership of Reagan administration appointees, banned future in- stallations of UFFI as of August 10, 1982. No UFFI may be in- stalled in any residential or school building subsequent to the August deadline as the material presents an unreasonable health risk. The Commission concluded that formaldehyde gas, which is emit- ted from the insulation after it is installed in the walls of a home, has been established as a carcinogen in rats and mice and is a highly suspect human carcinogen. The ban was established because the Commission found that no regulatory requirement, labeling, for example, would be effective in protecting consumers. Formaldehyde gas presents a unique problem because it affects each individual differently. The most susceptible groups to the PAGENO="0007" 3 harmful effects of formaldehyde gas are people with allergic, asth- matic or bronchial conditions, children, and the elderly. Formaldehyde gas has always been considered a problem which should be avoided to the greatest extent possible in the workplace. It is, however, seen as a greater problem in the home because of the constancy of exposure. I leave it to this subcommittee to determine why the CPSC voted to allow installations to continue for 6 months after reaching its conclusions. I will only note that installations between February, when the CPSC rendered its decision, and August will serve to compound the central issue which this subcommittee is investigating: What is the proper role of Federal, State, and local government in uncovering and remedying the problem that may exist in homes throughout the country where UFFI has been installed? A number of States have taken action in this area both before and subsequent to the CPSC's decision. Our home State of New York is offering free laboratory testing to consumers who obtain a physician's request for testing. The CPSC estimates that approximately 435,000 homes are insu- lated with UFFI, 70,000 of which are in our home State of New York. A substantial number of the homes are located in the eight west- ern New York counties-10,000 in Erie County alone. The regional office of the New York State Department of Health has received over 700 requests for formaldehyde gas monitoring in the Buffalo area since the beginning of 1982. Unfortunately, staff and budgetary constraints have only allowed them to complete about 20 examinations per month since that time. Some county health departments have begun to do their own monitoring, but because of very limited facilities, the testing of all the homes will be a long drawn out process. Two of the most prominent and controversial State initiatives have come from Massachusetts and Minnesota. A 1980 Massachu- setts law required the UFFI manufacturers to remove the foam from the walls of a home when a health risk was determined to exist. That determination was to be made by the Massachusetts State Health Commissioner who was to make his decision based on the severity of the health problem and the State-sponsored testing of the home. The law was found to be unconstitutional by a Massachusetts court which ruled that the law denied the manufacturers their due process rights. The case is currently under appeal. Subsequent to this decision, Massachusetts was forced to give up free testing as a result of funding cuts under proposition 2½. In 1980, Minnesota passed laws governing the sale of building materials and new housing units containing UFFI. The Minnesota State Commissioner of Health determined that the maximum al- lowable level for these new dwellings containing UFFI would be 0.1 parts per million. The standard has recently been raised to 0.5 parts per million. PAGENO="0008" 4 Several other States have introduced bills to ban or impose a moratorium on the sale of UFFI, to set performance requirements, or to require safety related disclosures. The Canadian Government recently banned the use or sale of UFFI. Their program, which I can only briefly outline here, has been very effective in dealing with the problem. The Canadian Government offers universal free testing to con- sumers. The Government provides consumers with testing meters on which they can take initial readings. In the event that there are hazardous levels present or that there is an apparent health problem, the Government offers subsi- dized full scale testing at a cost of about $100. Government testers disclose the results of the full-scale tests to the homeowners and when necessary make remedial suggestions to the homeowner. If the full-scale test determines that the degree of risk warrants the need for remedial action, the Government provides a nontaxa- ble grant of up to $5,000 to the homeowner for the remedial action. Because the removal process is very difficult, the Canadian Gov- ernment requires that all remedial work funded by the Govern- ment program must be done by contractors who are certified by the Canadian UFFI Center. Finally, as there have been many reports in Canada of difficul- ties in resale and renewal of mortgages for homes insulated with UFFI, the Canadian Mortgage and Housing Corporation has estab- lished a program to provide mortgage insurance for these homes. While the problem is far more pervasive in the United States- about 435,000 homes affected as opposed to about 80,000 in Canada-I do feel that the program offers us an important frame- work to consider. So far, the only remedial action which has been found which will substantially mitigate a high risk situation is complete removal of the foam from the walls. Even when this is done, the residues ab- sorbed into the surrounding wood still may be present, but their ef- fects have been proven to be minimal. This method is, however, very costly and inconvenient because walls have to be dismantled to remove the foam. The approximate cost of this operation is estimated to range from about $3,000 to $25,000 according to the CPSC, dependening on the size and charac- teristics of the home. Removal of the foam may not always be the wisest option. First of all, the potential health risks decrease dramatically after the rirst year. The CPSC has estimated that this decrease may be 50 percent or more after the first year. Also, for the consumer who finds no ad- verse health effects removal may not be necessary or desirable when a cost-benefit analysis is made. Other remedial actions have been suggested. Sealing all cracks, holes, and moldings with caulk or spackling is one method which may help to restrict the air flow and thus the flow of gas into the house. Coating the walls with water vapor barrier paint is also a method which has been considered, as well as removal of the gas from the air in the house by fumigation and air exchange. PAGENO="0009" 5 In summary, Mr. Chairman, an effective response requires coop- eration among all levels of Government in order that they may devise a plan which will allow not `only for the determination of the relative risks involved but also, when necessary, the proper re- medial response. This is the charge which I believe the subcommittee has as- sumed. I stand ready to provide whatever insight and aid that I can to see that it is fulfilled. Appearing with me today is Chuck Swanick, a distinguished Erie County legislator from the 10th district. Chuck has spearheaded ef- forts to explore and find remedies for the UFFI problem, and like you, I anxiously await his testimony. He will appear at your pleasure, either immediately before or after the panel. I am sure he has tremendous experience, insight, and vision for the future. I thank you. Mr. ROSENTHAL. Thank you very much for your useful, impor- tant, and significant testimony. Mr. Swanick will testify after this panel. We thank you for ap- pearing today. Our first panel this morning consists of consumers who have been exposed to formaldehyde products. We will ask all of you to come up and sit at the table as a group. We have Connie Smrecek, national coordinator of SUFFER, which is Save Us From Formaldehyde Environmental Repercus- sions; accompanied by Marc Kurzman, consulting attorney for SUFFER; Marianne Barth, Gary M. Prisand, Jeanette Geller, and John and Cathy Lovejoy. It is the intention of the subcommittee to visit the mobile home which is parked outside between the Longworth Building and this building at the conclusion of the testimony, which we anticipate will be at 12 o'clock. Make yourselves comfortable. Our first witness will be Connie Smrecek who will give us some overview of this situation. Let me say that we are delighted that all of you are with us. We are sorry for the reasons which exist for your being here, but having said that, we want to extend our warmest welcome from the Congress to all of you. Mrs. Smrecek. You may proceed. STATEMENT OF CONNIE SMRECEK, NATIONAL COORDINATOR, SUFFER, ACCOMPANIED BY MARC KURZMAN, CONSULTING AT- TORNEY Mrs. SMRECEK. Thank you, Mr. Chairman. My name is Connie Smrecek. My family and I are victims of formaldehyde. In 1979, it was suggested: "If you feel better out of your home than you do in it, you may want to have the air tested for formaldehyde." My family and I had been sick and we were looking for more in- formation and help. PAGENO="0010" 6 Our home was tested and the level in our son's bedroom was 0.81 parts per million. That was the beginning of a search for more in- formation, eventually leading to communication with approximate- ly 8,000 consumers, workers, and other victims and the founding of the national consumers group called SUFFER, which stands for save us from formaldehyde environmental repercussions. We have chapters in about 40 States and Canada. I beg you to have an open mind as I tell you of our own story and as I repeat to you some of the statements made to me in my work as national SUFFER coordinator. The stories sound unbelieveable. Only those who have lived through it could truly understand the hell endured in this huge formaldehyde human guinea pig experiment. While I appreciate this opportunity to represent the formalde- hyde victims, my goal is to return to the life of a homemaker and a private person. My 11-year-old son, Jason Smrecek, has been brain damaged, which his doctors tell me was caused by formaldehyde. In a 2-year span Jason went from the 70 percentile down to the 12 percentile in the memory portion of his physiological exam. This happened after we installed 35 pieces of 4 by 8 foot ½-inch particle board in our 65-year-old home. Our lives between February 1977 and May 1979 consisted of constant throat cultures for strep throat, severe crabbiness, fatigue, even though we spent many hours day and night sleeping. We had the usual eye, nose, and upper respiratory irritation. My husband, Tom, who was in his early thirties, had such severe ar- thritic symptoms that he could not stand up straight when rising. Many times we listened to our son's breathing, wondering if the next breath would come. Our immune systems were altered so we could not fight off the slightest cold and each of us had our own symptoms. When our house was tested 2 years after installing the particle board, our level was 0.81 parts per million. We removed the parti- cle board in July 1979, bringing the level down to 0.03 parts per million. However, by then we had become sensitized to formaldehyde and other chemicals. Because of our sensitization, our lives basically are limited to Jason and Troy attending elementary school and my husband going to work. We have to limit our friends to those who do not smoke or wear perfume or aftershave or live in homes that we can only tolerate for an hour or two. When my son's 8- and 11-year-old friends come to visit our home, the smells in their clothes even leave us feeling listless and person- ality changes occur. In other words, if we wish to feel human, we must be prisoners in our own ecological home. For example, being hypersensitive means that: One, if we are out of our house for too long a time, such as in 1981 when we made a 3-day Christmas visit to our son's grandpar- ents, it means weeks of recovery time for us. PAGENO="0011" 7 Two, when we need to eat at a restaurant, it means walking through a smoky, scented environment and eating food that will make us sick. After arriving home we must remove all of our clothing and shower as the smoke and perfume cling to our bodies, hair, and clothing. Three, reading materials-we have difficulty with many because print is set with formaldehyde. The more colorful the page, the more formaldehyde is used. Four, synthetic materials cannot be tolerated on our skin. It is very difficult to find and expensive to purchase clothing that is of natural content. Five, personal care products. I am unable to use cosmetics and only a few natural oils. Baking soda is used instead of toothpaste. Shampoos are extremely difficult to find, as are soaps. A bar of soap in a soap dish at a friend's house can leave us with severe reactions. Six, shelter. We have been very fortunate to build an ecological home. It is our only haven from your world. Hotels and motels make us sick and we have to take with us our own sheets, pillows, our own soaps and towels. Seven, as for cleaning products, ammonia and bleach cannot be brought into our home or used at all. There have been only two laundry soaps that I can slightly tolerate and then I have to use baking soda with it to remove the fragrance. Even the odor from floor wax at a friend's house is intolerable. Eight, is public transportation. Car pools, vehicles of friends and family, the smell of perfume there, aftershave, tobacco smoke, and cleaning products dictate the use of this type of transportation. The smell in new automobiles is formaldehyde. Car exhaust gives off formaldehyde. Therefore, all windows and doors must be shut before the car is started and the car must be shut off before getting out. Numerous things in the school environment affect Jason and Troy's learning-from cleaning products to the printed materials to the personal care products used by other children and the teachers. There is also the schoolbus fumes. These are some of the problems which the sensitized families must deal with on a day-to-day basis. We live in constant fear of what the immediate future holds for us. Will we be able to breathe as we walk through the stores or down the sidewalk? Will my child be able to kiss his grandmother good- bye? Or, will the fragrance left lingering on her clothes prevent him? Are the cleaning products used on the classroom floors preventing Jason and Troy from obtaining their rightful education? As an adult, will he be able to afford an ecological home? Or will they have to live on welfare? Will they be able to have healthy children? Our other acute problems are behind us, but what about the future? We are told there is a strong likelihood--- Mr. ROSENTHAL. Where are you now? I have lost you. Mrs. SMRECEK. I am on page 4. PAGENO="0012" 8 Mr. ROSENTHAL. I would like you to skip over some of the stuff about cancer in rats and let some of the specialists tell us about that. What I am interested in hearing from you is your personal story without much of the rest of it. We have so many people who can personalize this. I think that would be the most helpful thing for you to do. Mrs. SMRECEK. I have removed a lot from the written presenta- tion for my oral statement. In my oral statement I have removed much of the written. Mr. ROSENTHAL. I am trying to get you not to read your state- ment and just tell me what it means to you as a person. Tell me what happened to you. Cover that statement up so you do not read it. Mrs. SMRECEK. All right. I would ask that my full testimony be placed in the record. Mr. ROSENTHAL. Without objection, so ordered. Mrs. SMRECEK. When I go out in public, I become affected. It af- fects the way 1 walk. Mr. ROSENTHAL. Does smoking bother you? Do you want me to get rid of the smokers up here? Mrs. SMRECEK. You do not have to get rid of them; just the smoke. Mr. ROSENTHAL. Would you please put those out? Mrs. SMRECEK. Thank you very much. It means after you have become sensitized, it means a totally dif- ferent way of life. Mr. ROSENTHAL. In what way? Mrs. SMRECEK. You have to remove from your environment every substance such as perfume. If you were to go through your own home and look at every can, every bottle, every box in your home and read your ingredients, you first of all would have to take away from your home everything that has the word "fragrance" on the label. I was told by a chemist that anything with "fragrance" on the label can have formaldehyde in it. Fragrance affects us severely. It is the same with tobacco smoke. I was told one cigarette can off-gas 30 million to 40 million parts per million of formaldehyde. I believe you will also find that formaldehyde may be sprayed on the tobacco leaves. So anyplace we go where there is tobacco smoke, it can affect my breathing, my walking, my talking. Mr. ROSENTHAL. In what way? Mrs. SMRECEK. There have been times when my feet do not want to flex when I walk. Mr. ROSENTHAL. Did you ever have any of these problems before all this took place? Mrs. SMRECEK. No, sir. Mr. ROSENTHAL. Go ahead. Mrs. SMRECEK. There have been times when my left foot would drag. It would just drag behind me. There are times when I am being exposed that I have trouble re- membering what I wanted to say. That is one reason I had the written testimony. Mr. ROSENTHAL. Tell me about your family. PAGENO="0013" 9 Mrs. SMRECEK. A good example is this. My son, Jason, is 11½ years old. He went to an arrow of light program for the Boy Scout program. This weekend he camped out for two nights. When he came home he was hyper; his arms fly like a bird. He is so hyper. We feel it is from the smoke from the campfires. Perhaps the tents have been sprayed. Perhaps it is the smell in the tents from other things the other boys bring. It can be from the gasoline stove, the camp stove used. Mr. ROSENTHAL. This is a very silly question. Why do you let him go do these things when you can anticipate these problems? Mrs. SMRECEK. I could keep him home. I would like to. How can you keep an 11½-year-old child at home constantly? He can go and have his exposure and have his fun and come home and perhaps take a week to recover. Or I can keep him home constantly and suffer probably psychological problems. I have my choice; yes. My son, Troy, who is 8, when he visits a friend-and he visited a friend just this last weekend-when the other parent drove him home, the friend's parent, he was smoking in the car. How can I tell everyone: "OK, my son can go to your house if you do not smoke; if you remove the room deodorizers from your house; if you do not use any sprays in your home; if you do not have particle board flooring in your home; and if you do not have carpeting in your home." Mr. ROSENTHAL. Has the condition gotten better or worse or changed in any way? Mrs. SMRECEK. The sensitivity to it increased, I feel, after the particle board was removed. This seems very, very common with all the people I have talked with on the telephone from other parts of the country, the people who have lived in these homes, too. Oftentimes the people living in those homes think or perhaps they are told that if they remove the source of the problem, that is it. They are going to be healthy again. They do have to remove the source of the problem to start feel- ing better. But you do not automatically feel better and stay better. Oftentimes the people do become sensitized. It is after you clean up your body trying to get the formaldehyde out of your body first that when you are reexposed, such as going to an airport to come here today, such as getting into a taxicab-all of those exposures add up to too much. Your body cannot handle it again. It is like living in that house all over again. Mr. ROSENTHAL. I do not understand. Does formaldehyde appear in the airport and in the taxi? Mrs. SMRECEK. There is tobacco smoke at airports, the petroleum products; perhaps the floor wax that is used is there. Perhaps there is exhaust from the cars and the jets. There is perfumes and aftershaves. Those products are every- where. They are wherever you go. Unless you have an ecological home and can hibernate, you cannot avoid them. Mr. ROSENTHAL. How long has your situation continued? Mrs. SMRECEK. We removed the particle board from our home in July 1979 and we built an ecological home and moved into it on August 15, 1981. So we have just been in there a few months. PAGENO="0014" 10 Mr. ROSENTHAL. Has your condition improved or changed? Mrs. SMRECEK. If I am in my home; yes. I can almost be normal again-I can comprehend things; I can read; I can talk; and I can play with my kids. For instance, coming here might mean a week, a month, of sleep- ing 10, 12, or 14 hours during the night, sleeping 2, 3, or 4 hours in the afternoon, for months. It can mean-- Mr. ROSENTHAL. Have the doctors told you at all how long this disability will last? Mrs. SMRECEK. As I understand it, the sensitization aspects are permanent. As long as we can remain free-as free as possible of the chemicals-we can be better. But if you are exposed again, like the boys going to school, they are being exposed, then-- Mr. ROSENTHAL. It has been 3 years since your home was cleaned out; is that right? Your experience is that you are still suffering to the same degree of sensitivity as before? Mrs. SMRECEK. Not if I am in my ecological home. Mr. ROSENTHAL. I mean outside your home. Mrs. SMRECEK. Yes; then everything comes back. I was having severe problems in the motel room last night. I had problems at the airport and coming here today in a taxi. Mr. ROSENTHAL. Is there anything you can do to alleviate the sit- uation? Mrs. SMRECEK. One thing that I know of is oxygen will help cleanse your system so that you can feel better again. When I asked for oxygen for my son when he could not breathe in the car a couple of times, he refused us saying that oxygen is very expensive and he would not know how to explain it to the in- surance company. We do not have oxygen. [Mrs. Smrecek's prepared statement follows:] PAGENO="0015" 11 May 18, 1982 Presentation before the Commerce, Consumer and Monetary Affairs Subcommi ttee ofthe Committee on Government Operations, U.S. House of Representatives Presented by Connie Smrecek, National SUFFER Coordinator BOARD OF DIRECTORS Connie Smrecek Joan Oien Judith Ulseth CONSULTING ATTORNEY Marc G. Kurzman ADVISORY BOARD Professor, Wash. U. Peter A. Breysse PAGENO="0016" 12 My name is Connie Smrecek, (RR1A, Box 148C, Waconia, MN 55387; phone 612-448-5441) It was back in 1979 when reporter, Larry Schmidt, suggested, "If you feel better out of your home than you do in it, you may want to have the air tested for formaldehyde." For two year before, we did feel better out of the home. That was the beginning of a search for more information eventually leading to communication with 5pprodmatelY 8~OOO con- sumers, workers and other victims and the founding of a national consumer's group called SUFFER (Save Us From Formal- dehyde Environmental Repercussions). I beg of you to have an open mind as I tell our own story and as I repeat to you some of the statements made to me in my work as National SUFFER Coordinator. The stories are unbelievable as only those who have lived through it could truly understand the hell endured in this huge formal- dehyde guinea pig experiment. While I appreciate this opportunity to represent the formaldehyde victims my goal is to return to the life of a home maker and private person. PAGENO="0017" 13 PERSONAL STORY OF THOMAS AND COBBlE S~ECEK AND SONS JASON~j1, AND TR~ 8 Eleven year old son Jason Smrecek has been brain damaged which his doctors tell me was caused by formaldehyde. In a two year span Jason went from the 70th percentile down to the 12th percentile in the memory portion of his psychological exam. This happened after we installed thirty-five pieces of x 8' ~" particle board in our sixty-five year old home. Our lives between February, 1977 and May, 1979 consisted of constant throat cultures for strep throat, severe crabbiness, fatigue, even though we spent many, many hoursaday and night sleeping. We had the usual eye, nose and upper respiratory irritation. Tom, who was in his early 30's, had such severe arthritis symptoms that he couldn't stand-up straight when rising. Many times we listened to our sons breathing wondering if the next breath would come. Our immune systems were altered so we couldn't fight off the slightest cold, and we each had our own symptoms. After two years our level was .81 ppm. We removed the particle board in July of 1979 bringing the level down to .03 ppm. However, we had become sensitized to formaldehyde and other chemicals, as well as developing food allergies. Because of our sensitization our lives now are basically limited to Jason and Troy attending elementary school and my husband Tom going to work. We have to limit our friends to those who do not smoke, or wear perfume or after- shave, or live in homes we can tolerate for an hour or two. When my sons' 8 and 11 year old friends visit our home, the smells of their gum and fabric softener in their clothes leaves us feeling listless and personality changes occur. In other words, if we want to feel human again we must be a prisoner in our ecological home. 97-153 O-82----2 PAGENO="0018" 14 A three day Christmas visit to the boy's grandparents meant weeks of recovery time for .us. When we need to eat at a restaurant it means walking through a smokey, scented environment and eating food that will make us sick. After arriving hose we must remove all our clothing and shower as the smoke and perfume has contaminated our bodies, hair, and clothing. Reading materials: Print is set with formaldehyde, the more colorful the the page, the more formaldehyde is used. This includes school books. Plastics: Plastics give off hydrocarbons and formaldehyde is from the hydrocarbon family. The warner the plastic gets the more hydrocarbons are given off. This relates to: 1. Holding a plastic telephone 2. Operating a TV or radio 3. Plastic dishes J~. Food wrap 5. Sitting on Vinyl upholstered furniture (home or car) 6. Toys Synthetic materials: These cannot be tolerated on our skin and it is very difficult to find, and expensive to purchase clothing that is of natural content. Even then, chemicals are still used. Leather is tanned with for- maldehyde and glue is used in making shoes. Personal care products: I am unable to use cosmetics, only a few natural oils. Baking soda is used in place of toothpaste. Shampoos are extremely difficult to find, as are soaps. A bar of soap in a soap dish at a friend's house can leave us with severe reactions. Shelter: We have been very fortunate to be able to build an ecological home. It is our only haven from ~ world. (See newspaper clippings.) Hotels! PAGENO="0019" 15 motels make us sick. We must ask that only water be used to clean the room; even then the chlorine gives us immediate reactions. We need to tmke with us our own sheets and pillows, along with soap and towels. Cleaning products: Ammonia or bleach cannot be bronght into the home or used at all. There have been only two laundry soaps that I can slightly tolerate and then I have to use baking soda with it to remove the fragrance. Even the floor wax at a friend's home is intollerable. Work environments * The future may tell us that my husband Tom can no longer continue as an aircraft mechanic due to the fumes. Will Jason and Thoy be able to support themselves or will their sensitivity to the outside environment dictate their health? I can only function in my own home and then only if I haven't visited ~ world. Public transportation, car pools and vehicles of friends and family: The smell of perfume, aftershave, tobacco smoke and cleaning products dictate our use of this type of transportation. Automobiles: The new car smell is formaldehyde. We need to look at older cars in which the owners did not smoke or use perfume. Ideally, the air from the engine should be blocked and an air cleaner used inside. Car ex- haust gives off formaldehyde, therefore, all windows and doors must be shut before the car is started and the car must be shut off before getting out. Two times while traveling from our home to Minneapolis Jason grabbed his throat saying he couldn't breathe. I asked his doctor for oxygen and the doctor refused saying it is very expensive and he wouldn't know how to ex- plain it to the insurance company. A dose of pure oxygen wifl relieve symptoms. Schooling for the children: Numerous things in the school environment affect Jason's and Thoy's learning. From the cleaning products to the printed material to the personal care products used on the other children and teachers to the school bus fumes. What are the alternatives? PAGENO="0020" 16 Neighborhood pollutioni If a neighbor, even one-quarter mile away, is burning wood and the smoke flowing in our direction, all doors and windows must be closed, The same for tarring of a road, chemicals being used on a field, a car left running or a neighbor charcoal grilling. These are some of the problems which the sensitized families must deal with on a day-to-day basis. We live in constant fear of what the immediate future holds for us. Will we be able to breathe as we walk down the sidewalk? Will my child be able to kiss his grandmother goodbye or will the fragrance left lingering in her clothes prevent him? Are the cleaning products used on the classroom floor preventing Jason and Thoy from obtaining their rightful edu- cation? As adults will they be able to afford an ecological home? Or will they have to live on welfare? Will they be able to have healthy children? Cancer - - In one cancer study formaldehyde produced cancers in k5% of all the animals tested. However, almost 100% of the ~ tested ended up with cancer of the respiratory system according to a CPSC scientist. In another study Dr. Infanti's Jan. 19th memorandum related human cancer to formaldehyde exposure. The victims must live with this thread of anxiety and fear of cancer along with health problems of hypersensitivity, brain, and nervous system damage. PAGENO="0021" 17 Avoidance of formaldehyde and other potent chemical exposures is the first and foremost method of treatment of formaldehyde sensitivity and general chemical susceptibility. Joyce, a lady in her twenties, is not as lucky as we are. She lives through the support of her father but she can't live in his house, as the fumes from the other people make her sick. She can't go outside her home to get her mail; when someone brings her the mail it must be "aired" first, sometimes for weeks, She can't have a TV either because of the emitting fumes. There are only about a dozen foods that she can eat and these must be eaten in rotation, every four to seven days. If she has an exposure to formaldehyde, even a minor exposure, she can't tolerate some of her allowed foods. She also uses oxygen. Victims often cannot get help from their physician, Sharon writes, "Our problems were first noted when our four year old son was a baby. The physicians were ignorant to the source of the problem. By age two he was having uncontrolled seizures and screaming spells lasting two-three hours along with respiratory problems and others, Our second child at age two months stopped breathing on two different occasions. This baby was sleeping in a panelled basement bedroom in which we later learned was off-gassing formaldehyde. Our older son's violent behavior problems were serious now. He caused serious physical injuries, such as several concussions and separated shoulder, to the younger child, In four years he never slept the might through, he always woke up at two hour intervals until the particle board was removed from his closet. We soon learned this violent behavior was only triggered at home. When out of the home he can be cooperative, calm and pleasant, PAGENO="0022" 18 It was when our dog died of kidney failure that the vet discovered our family had many health problems. It was the vet who suggested the health department run an air check. The medical profession's inability to recognize multiple sets of symptoms are compounding the victim's problems even though JAMA (Journal of the American Medical Association) printed such articles. Oftentimes the patient's tests are all negative so the doctor assumes it is all in the patient's head and suggests te pale see apsyc~4~gis~, One lady, who lived in a mobile home, was told by her Mayo Clinic physician -- we don't know anything about formaldehyde and we don't want to know anything. Another lady's physician said that Minnesota doctors refuse to test for formaldehyde sensitivity because they could be sued if the patient got cancer? There have been a few physicians who have recognized the problem and actually refused to release the child if the parents intended to take the child back into the home, or told the patients not to go back into the home. These physicians are few. The medical profes~on needs tp~~ ~ e~at~e~noW. Deer Creek, Souix Falls, South Dakota Gary and family writes~ In October 1979 when we moved into our new home we had no unusual health problems. Within a year our four year old daughter developed severe breathing problems and was treated by our physician for cold ailments. Later she was diagnosed by a doctor in Wisconsin as having severe sensitivity to formaldehyde and at the doctor' m advice removed her from our home. Cherie, who lives in the same sub-division writess Our four month old daughter was healthy when moving into our home in August of 1979. At ii months she stopped breathing and had seizures, PAGENO="0023" 19 Barbara, who also lives in the same addition writes; At three weeks our new son was diagnosed as having a very rare disease in which the adrenal glands do not produce hormones or steroids, later we took him to an allergist who confirmed our suspicion that Matthew's illness was not this rare disease but formaldehyde poisoning. Where does one go or a family with three or five young children go when forced to evacuate their hose? Some have lived in a tent in the back yard, some in sleeping bags on the patio, some move into the basement or bedroom of inlaws. An elderly lady slept in the back seat of her car, even on cold nights in northern Wisconsin, These people can't afford two house payments. Where can they go? We've become the "Canaries in the mine shaft." When these people realize .they have an invisible gas in their homes they begin to look for answers. They contact theirs fire stations police departments city health nurse/doctors universities attorneys luniberyards mobile home dealer Federal Government CPSC Major clinics/medical centers and local county and state health departments Their questions are left unanswered. Eventually they contact SUFFER. SUFFER has grown Into a national consumer group by the mere act of looking for information. So many victims are contacting us, there is no way we can stop now. For weeks after a national TV broadcast and CPSC `s courageous vote to ban UFFI, we received 7~ to 200 phone calls and letters daily. History; SUFFER is a grassroots-type organization established by concerned persons who have suffered from the health, emotional and financial PAGENO="0024" 20 effects of living and working in areas contaminated by chemical substances, the most prevalent being formaldehyde. Activities; 1) To provide information and educational material to the public about possible hazards, remedies and safeguards involving chemicals used in construction and remodeling of home and work areas. 2) To aid families and individuals who have in fact suffered from the effects of chemical poisoning especially from sources over which they have no control. Purpose; To promote the general welfare of the public and preserve the right of the individual to live and work in an environment free from hazards produced by the use of chemicals which can be detrimental to his/her general health and well-being. People from every walk of life have been contacting us for help. Most are victims but we are also hearing from schools, realtors, hospital personnel, physicians, chemists, attorneys, health departments on a county and state level, artists, firemen, beauticians, morticians, architects, land developers, luinberyards, and the list goes on. People are complaining not just from UFFI homes, mobile homes or conven- tionál homes with particle board but also from an older home without major sources. The frame of a waterbed is oftentimes made of particle board. One doctor called saying he had particle board bunk beds made into the shape of a bus for his sons. They developed immediate upper respiratory symptoms. One lady pur- chased two tables of particle board. She couldn't tolerate them. Have you ever gone into an unfinished wood furniture store and looked at toy furniture for your children to play with? How much formaldehyde invades our dearest possessions? PAGENO="0025" 21 "Some people can be `adapted' to certain chemical exposures in such a way that they appear to experience no direct effects. This phase often pre-- cedes a `maladapted' state where obvious symptoms begin to occur. The ad- aptation can be `unmasked' by avoiding the chemical exposure for a while, then being re-exjosed to it." Bruce Small You can remain specifically adapted for long periods witlxut obvious ill effects. Once the maladaptation has occurred, susceptibility not only tends to increase in degree but appears to spread to related chemicals. Experience with some physicians is that at some point adaptation could break down, resulting in illness, acute sensitivity to formaldehyde exposure and possibly widespread susceptibility to other exposures. Chronic illness ensures an adaptive abilities break down. A man from Florida contacted me saying that a few weeks after leaving his job of making mobile homes he had chronic illness. Another lady worked in a plastics factory and is now a recluse. How many unsuspecting consumer victims of formaldehyde poisoning are there? We have heard from several who moved into their homes three to eight years ago, have had symptoms of formaldehyde sensitivity, have particle board, UFFI in a conventional home or live in a mobile home. It is our contention that there is no limit on the number of victims. Formaldehyde is everyone `5 poison. Bruce Small, a Toronto environmental engineer, has written a book titled "The Susceptibility." He writes, "References in the literature on chemical susceptibility tend to caution that the `adapted' phases of response to low levels of the chemical can sometimes mask specific sensitivities. When this occurs the state of adaptation becomes the forerunner to later problems." Even when a victim has a clue that it is formaldehyde the testing is ~p~rd. One family in Georgia had the health department test her home but later said the results weren't accurate because they held the sample for one month before analyzing. PAGENO="0026" 22 In Massachusetts the manufacturer of the UFFI told the homeowner. who vacated his home to be sure to close all the windows the day before the test. The hose owner drove past the home at the time of the test only to find they had opened all the windows during the test. Many victims state that the manufacturer ~o11ected the air ean~1ee but re~ fused to release the results of the analysis. Many localities do not have access to private testing or government tests. There are several cells on the market which professionals are telling me are not accurate devices~ 1. They pick up all the aldehydes, not just formaldehyde. 2. One of them flooded the market when it appeared on "20/20," February k, 1982. Within a couple weeks they had sold tens of thousands. One doctor said the test should not be taken in January or February due to outside temperatures which affect inside for- maldehyde levels. 3. The people think they can use the cell over and over again but it's good for only one test. 1+. The instructions do not even tell the people to close windows and doors--many of the people who called us said they purchased the testing cell right after "20/20" aired in February and now have received their results--but they don't know what the results mean. In talking with them I learned that the window was opened and it was a windy, cool day. Too much emphasis can be placed on one test, especially if the home is not prepared. I do have with me a testing kit which is based on the chrosotropic acid test recommended by NIOSH and devised by Dr. Charles Jordan. It costs $65.00 for two tests or $85.00 for four tests. It is sent to the home via mail; the homeowner can have a witness, test his own home and mail the kit tack for lab analysis. The instructions are explicit and it also explains what the results mean. PAGENO="0027" 2~3 Another alternative is private testing labs which are expensive, sometimes as high as $1,100.00. Others say they can't locate anyone to test their home. Setting limits we have to remember formaldehyde is a sensitizing, poisonous chemical. If a limit were to be set on particle board for instance, what happens when an infant site on or falls asleep on a floor where particle boar~ subilooring is used? The manufacturers of - formalde~~yde1)rodUct5 need tobe held~ccountah~~ In 1972 the industry had received health èomplaints from consumers and did a study. They learned that formaldehyde outgassed from their wood products, but also made the decision to ignore it. At the Minnesota House Health and Welfare subcommittee hearings in April of 1981 a bill setting a limit of * 1 ppm was tabled and killed. The industry's main points of defense were s 1. A standard of 0 * i is incapable of being met because it costs (do you believe this!) $600.00 to test air and $1,000.00 to determine ambient air. 2. The cost of building a mobile home with a 0.i ppm standard would add $2,500.00 to the price of the home. (How many of you victims would rather pay the $2,500 .00 than your medical bills or the cost of moving and losing your entire home?) 3. Industry believes standards on the products themselves should be utilized. In fact they said such a schedule of standards was being set up and would be publicized in two weeks! PAGENO="0028" 24 That was the point at which the bill was tabled to wait for these `self imposed product standards" to be announced in two weeks. The 1981 session of legislature ended and not one word has been heard from the industry about the standards. The industry has known for years that formaldehyde is a sensitizing chemical poison yet they continue to lie to reap profits. Please don't allow the industry to continue putting people's health and lives on the line for their profits. It is time for them to be held accountable for their actions. We can no longer tolerate this crime. There are so many victims that continue to live in these foraaldehyde contaminated homes with their young children, or the elderly in federally subsidized housing. These people cannot afford to move, make an extra house payment or rent payment; or they have no friend/ relative to move in with. Literature, copyrighted in 1976, by American SPE Corporation, exclusive US distributor of Aerolite Foam, list their product as not constituting any significant toxic hazard. A letter dated 2-5-82 from TEDO to Furman Lumber, Inc. states, "It seems very unlikely that the waferboards you are selling would contribute to formaldehyde vapor in shelter." Ammonia, air wicks, sealants and simple filters are suggested by the industry as a means of treatment, yet they know these things do not provide permanent safety measure. PAGENO="0029" 25 Consider the Economics: How formaldehyde building materials increase government costs and slow down the economy. 1. Many adults become too sick to work or care for their chil- dren: Increased social security and welfare. 2. The elderly become more sickly: Increased medicare. 3. People become hypersensitive to popular products, etc.: loss of business for public transportation, restaurants, and entertainment businesses. ~ Children unable to concentrate in a contaminated school: Unproductive and under-educated adults unable to work up to their potential. 5. Professional workers of all types unable to concentrate or control their emotions in order to make decisions or do the work they are being paid fori Increased insurance for health benefits, increased sick time, and loss of productivety. 6. UFFI homes are harder to sell: devaluation of property and taxes. 7. Many victims have had to resort to ~ PAGENO="0030" 26 Assistance for the victims .A lady wrote: I was very pleased to receive a copy of The Environmental Guar dian. I'm only sorry that such publications and assistance were not available two long years ago." That letter was submitted in late 1980 and it is now another long two years later. Why is the government still allowing formaldehyde to kill our children? Joan Lohnes, another of the Deer Creek, Souix Falls, S.D. homes, writes, "Our 2~ year old daughter, Heather, is brain damaged from formaldehyde poisoning. We moved into our new home in Oct., 1979. By the 8th month the doctors at the Mayo Clinic thought she had a rare form of brain cancer, but no tumor was ever found, Heather was comatose for months and finally cane out of it in Dec. 1980, but these episodes were repeated in May 1981 and Sept. 1981. She was hospitalized eight times, each time she was comatose and almost died. In Oct. 1981 we discovered we had formaldehyde in the air in our home." Joan credits SUFFER's newsletter, The Environmental Guardian, for saving the life of her friend's infant daughter. Joan read our article about the possible relationship between formaldehyde and Sudden Infant Death Syndrome. She took the article to their physician and he was astute enough to place the infant on a mon- itor. Indeed, the baby did have several episodes of apnea and stopped breathing and might have died. PAGENO="0031" 27 The person who wrote that article on SUDS was Carol Palmero, SUFFER's medical researcher. Mrs. palmero was L~8 years old and held a Bach- elor of Science degree in nutrition. Carol lived in a IJFFI home. She died on April 29th of this year of liver damage. It is the wish of the members of SUFFER that the government share with industry (who knew that formaldehyde was a health threat by the 1960's) the burden of financial assistance to homeowners. Example: Government knew there was a possibility that the swine flu vaccine would cause illness to some individuals. As a result government paid the damages for any illness caused by the swine flu vaccine. Since 1977 government has knc~vn about urea-formaldehyde in UFFI and the resulting off-gassing, yet continued to encourage the UFFI business. The Energy Act provided for tax credits to home- owners who insulated their homes with tJFFI as well as other in- sulations. Financial assistance should include immediate relocation, repair of home, and medical and legal assistance. - - (I submit a copy of the Cana- dian Assistance Program for UFFI Homeowners Progress Report, April 6, 1982, see page 5.) PAGENO="0032" 28 Exc~ts taken from 1980 Michigan newspapers. (A) In the wake of a class-action suit filed last week on behalf of nearly 350 Pine Grove residents over ailments allegedly caused by the insula- tion of UFFI in housing units, the University is initiating steps to aid those residents who wish to. leave the housing complex. (B) `Her doctor told her to move out because she is sensitive to the formaldehyde. Little children were playing with the foam where it seeped out of light fixtures and wall sockets." (c) The insulation was blown into the walls of the complex this summer as part of a $500,000.00 energy-savings program paid for by the U.S. Department of Housing and Urban Development. (D) Colburn said the Department can only inform the residents of the results but cannot take any enforcement measures to solve the problem. (E) The foam, which is blown into the cavities of outside walls in such buildings, is approved as an insulator by HUD and the state. (F) "This is a known fact that the formaldehyde gas can react with the hydrochloric acid in the (human) mucous membranes and form BCME, a known carcinogen." Cbs said. Excerp~ts taken fr~~ersonal letters to SUFFER Pamela says, "The Virginia Beech Board of Health came out to take the necessary air test, but held the test a month before getting a lab to test it." Nargery says, "My son died in his sleep in a mobile home of undetermined causes." Martha says, "I moved into a new Redinan mobile home. I became ill from the beginning--a peculiar kind of illness. I have been here one year. I weighed around 150 pounds and now weigh 110 pounds. For months I felt that I would not wake up the next morning. PAGENO="0033" 29 Jack says, "I had nosebleeds and bronchitis, along with other symptoms that progressively got worse the longer I worked there. I recently lost my job as a cabinet maker due to formaldehyde poisoning. My employer denies all responsibility." Jill says, "My daughter was sick ever since we moved into our mobile home. They even thought mhe had cystic fibrosis." John says, "My wife has suffered from an asthma condition since moving into a mobile home approximately eight years ago." Bertha says, "We thught a mobile home four years ago. There was a terribly strong odor that made us cough and eyes water. I developed breast cancer two and one-half years ago." David's wife says, "In December of 1978 our home was insulated with UFFI. Since that time our family has been plagued with respiratory problems. Our 7 year-old daughter is now on asthma medicine. I have been through the Mayo Clinic in Rochester, Minnesota. For three months I slept twenty-two hours a day, no appetite, dizziness and some feeling of numbness in my extremities and head. After a complete physical, brain scan, ERG, blood tests--I was told to go home and sleep it off!" Patricia says, "We installed particle board subflooring and kitchen cabinets. That same week our pediatrician diagnosed our six month-old son as having asthma. My four year-old son developed asthma the past year," Wallace sayst `Our first baby was born two and one-half months early and subsequently die d. Our second baby was born one month early. We live in a mobile home. Could this be related?" Mary sayss "A young teacher two months pregnant was spending eight hours a day teaching in a brand new mobile hose purchased by the school to provide 97-153 O-82--3 PAGENO="0034" 30 extra classroom space. She immediately began having severe headaches, pain- ful eyes and respiratory problems. The school officials aired the trailer. The teacher was released from her contract in the six month of pregnancy. The child was born with respiratory problems, digestive problems. For two years the hi's regular breathing sounded like a snore. Now at the age of four he has severe speech problems. He vomited h~is food after every feeding. No specialist could understand why." Ann says, "In 1980 I had Thipolymer foam insulation installed. I was assured at the time that this particular type of foam did not contain urea formalde- hyde that it was safe, and that it was used by NASA in Project Tech..' Barbara says," My medical records- show increased respiratory infections, throat infections, etc., increased significantly when my work required a move into a trailer. Later, because of work during a three year period I was also exposed to formaldehyde insulation. Then some five years ago my exposure would have been increased to nearly 24 hours each day whe:n we purchased a double wide trailer to live in. Symptoms now aret A. Nasal polyps and/or a~ute nasal irritation resulting in tumors which may be benign or malignant. B. Continuous mucous associated with infections of the nasal passages, throat and upper respiratory tract. C. Severe headaches. D. Respiratory damage causing asthematic conditions and resulting in a dependency on medication and/or oxygen as a means of dealing with breathing difficulties. E. Sores which break out on the surface of the skin similar to an acne condition. Sixteen employees of the Th.rrant County Courthouse write, "During the past two months each and every girl has had to leave work because of heavy fumes. We have employees, with allergies, emphysema, pregnant, and other physical conditions that are enhanced or endangered because of the irritation. Formaldehyde test results shcwed 1. ~ ppm." PAGENO="0035" 31 A doctor at the Mayo Clinic told his patients that we don't know anything about formaldehyde and we don't want to know anything about formaldehyde. One patient's doctor said we can't test you for formaldehyde sensitivity in Minnesota for fear of being sued. Since a sheet of particle board was placed under my son's mattress to support the mattress he's begun to have upper respiratory problems. We knew we were in trouble when all the flies were dead in the morning. I live in a mobile casket, I've been embalmed alive! I must travel out of the. state of Minnesota for a doctor who can treat my formaldehyde sensitivity with any amount of success. Expense per trip is $767.20 Excerpts taken from testimony by Ron Spong, formerly with the Bloomin~ton~ MN Health Department. (A) In October 1979, Knox Landing, a 15-floor high rise containing 212 one and two-bedroom apartments for senior citizens qualifying under HUD income quidelines, became a focus of our investigations when the index case (an elderly paraplegic with multiple sclerosis confined to her aprtment nearly 2L~ hours daily) complained that an odor eminating from her kitchen cupboards was resulting in congestion. breathing difficulties, watery eyes, etc,. . ,testin indicated that formaldehyde concentrations of 0.~9 mg/L were present in her apartment. PAGENO="0036" 32 (B) In conferences with the Boisclair Corporation's marx- agement officers, it was discovered that similar kitchen and vanity cabinets were installed in two other HUD Section * housing developments in the City of Bloom- ington, namely the Bloomington Townhouses and Penn Place. Excerpts taken from Minnesota's St. Paul Dispatch articles w~ittenby Alan Short (A) The Minnesota Health Department has learned it's easier to take on cigarette smokers than the formaldehyde in- dustry, even though both pollute indoor air. (B) A national indoor formaldehyde standard of .4 ppm would offer virtually no protection to an estimated 10 million to 12 million Americans who are "highly sensitive" to formaldehyde fumes. Medical research has shown that 4 percent to 7 percent of the population can be expected to become "sensitized" or allergic to formaldehyde after being exposed to it he said. That does not include the elderly or the very young. (C) "It's virtually impossible to build without particle- board," said Robert Stroot, property manager for the BoisClair Corp., developer and owner of the three Bloom- ington projects "I'm sure they (project residents) experienced some discomfort,' but I'm not sure it hurt them." PAGENO="0037" 33 Donna writes, "In December of 1980 I moved into a 1979 mobile home. On May ~f, 1981 my feet felt full of pins and needles and my nightmare began. The Minnesota Public Health Department tested my home. The level was 1.18 ppm." Anne says, "I have lived in the home a year, but some of my friends say their eyes burn at times when they come to see me and come into the house for as little as ten minutes. If I plan on having kids someday, and raising them in this home, I don't want to worry about any long term effects concerning the health of myself or my family." Laquita says, "Thank goodness there is someone like you to write to for requesting information about formaldehyde in particle board." William says, "A Rollchome representative said to place containers of ammonia in various places to reduce the odor, this we dad, however, we are still bothered." Ann says, "We have learned that the Rational Association of Realtors has sent out a notice that in Michigan homes with UFFI cannot be sold until the buyer and seller have signed and countersigned a paper stating that the buyer has been told of the possible effects, etc. that the insulation can have." R.L. says, "I bought a new mobile home in spring of 1979, for my wife who suffered from asthma, we moved in the home September 1979. Since we moved in, my wife `s breathing became worse * She was in the hospital a number of times th 1980. The last time she went in the hospital in October 29, 1980 and passed away November 15, 1980 of respiratory failure." A hospital nurse spent one-half hour cleaning up a broken gallon bottle of 1% formalin solution. That was two years ago and she has been home bound ever since. She did recently purchase a gas mask and can now finally attend church if she wears the mask during the service. PAGENO="0038" 34. David's wife states, "We've been in our new home for 6 years with severe health problems. I just learned about formalde- hyde. I've been contacting county, state and federal agencies and no one has been able to offer me advice, not even the Center for Disease in Atlanta," Another states, "My husband suffered a ruptured colon when in- stalling UFFI in a 23 story unit for the elderly." Joan said, "My children are dear to me and I love them. But several times while living in that house I would lock them in their bedroom so I wouldn't hit them. I would go through a lot of personality changes. I felt like the rats in the cancer study-- those that attacked and killed one another." Barbara writes, " I worked for Liberty Mobile Homes in the cabinet shop for 2~ years. Two weeks after my employment be- gan I had my first bronchitis attack. The first of many to come. Each subsequent attack became harder for me to recover. In Oct. 1978 my doctor told me I had no choice but to quit or else look forward to emphysema in the very near future. At which time he put me on Workers Compensation due to industrial bronchitis, which the company insurance accepted. I still have to be very careful around any caustic chemicals, ie. (house- hold cleaners etc.)" PAGENO="0039" 35 NEWS FROM THE SAVE~ ENVI R2~1A~ F ROM OCTOBER 1881 ISSUE 4 F E NVIRONMENTAL R EPERCUSSIONS HOW IS THE AIR IN YOUR WORKPLACE? Check this list of foomsldehyde Fertilizer Production 0.20 to 1.90 PPM levels in vsriraus industries. Dyestuffs +0.10 to 5.90 PPM The list of occupations that are Textile Muntiacture +0.10 to 1.40 PPM involved with exposure to HERO Resins (Non-foundry) ÷0.20 to 5.50 PPM is endless. A list can be found Bronze Fasdrj 0.12 to 8.00 PPM in the NIOSH Current Intelligenoe Iron Foundzl' ÷0.02 to 18.30 PPM Bulletin. The address is listed Theated Paper 0.14 to 0.99 PPM in this publication under "Media Hospital Autopsy Room 2.20 to 7.90 PPM Events". Plywood Industry 1.00 to 2.50 PPM NATIONAL SUFFER CONFERENCE? Due to easy requests fromexdioal professionals, legal professionals, and (aeon- ledgeable organizations, as well an victics, fo a conference to compare data, SUFFER is considering a National Conference i+ Minneapolis. We welcome coernerets. FORMALDEHYDE BY ANY OTHER NAME IS STILL ~ / Here is a list of "alternate" names for forcalinhyde and chemicals containing formaldehyde. Industry calls these names "idestifiers" and you can guess why they use them. Post this list where you ewe it daily. Chemical Abstracts Service Registry Hurter: 50-00-0 50005 RTECS ezueSer: LP8925000 Chemical Formula: ER20 & HERO BFV Karsan Fazuoform Lysoform Formaldehyde, gas Methylene oxide Formaldehyde, solution Methyl aldehyde Forcalin Methanal Farmalith Morbicid Formic sldehyde Oxomethsne Formal Oayeethylene Fyde Paraform Ivalon Superlysoform Preservatives in cosmetics and medications wttii contain formaldehyde: Donicil2~0 R (Inform your pharmacist) PAGENO="0040" *NATIONAL HEASXRJARTERS: Jeanette Geller 404-941-6033 GEORGIA SUFFER COORDINATOR Connie Smrecek 612-448-5441 P.O. 835 NATIONAL SUFFER COORDINATOR Lithia Springs, GA 30057 51019, Box 148C Waconia, RD 55387 Daniel A. Conners 208-524-1521 IDAHO SUFFER COORDINATOR Ann Miller 612-597-3572 1350 Shipp Avenue ASSISTING NATIONAL COORDINATOR Idaho Falls, ID 83401 RR2, Box 2418 Avon, RD 56310 Eunice R. MoCue 312-746-8792 Joan Oien 612-439-1920 *ILLINOIS SUFFER COORDINATOR ASSISTING NATIONAL COORDINATOR 1916 Horeb 12444 Partridge Court Zion, IN 60099 Stillwater,RD 55082 DEAR READERS This issue of The Environmental Guardian is a bit delayed. As youmay loiow, most of SFFER's won involves working with polluted papers and ink, and is cocpleted by sensitized volunteers who live many miles apart. Also, I hove had to nonage settlement of our family into our new ecological hone between phone calls. This has also led to the delay in responding to the deluge of letters. SUFFER is delighted to announce the addition of two new Directors, Joan Oien and Judith Ulseth. Some of you may have been in contact with Joan through her work as Assistant Nat'l. Coord.. Judith an also Assistant Editor, her articles began appearing in our last issue. Roth Joan and Judith are totally committed to helping SUFFER and are a great asset to us. Carol Palmero is our Medical Researcher (I failed to mention this in our previous issue). She has been doing extensive work in this field for sometime. Her articles help us to understand the medical aspectsof sensitization. You'll also notice Scot Sinnen's artistic talents beginning this issue. Scott is a high school student who is donating his time and talents to this cause. I sincerely hope you have enjoyed reading The ~y3rgppental Guardian and that you have found theinfermation of value. It was over one year ago that our family node a financial commitment to publish 4 issues of the newsletter. This has placed a great burden on op family, as it would on any one family, therefore this will be the last issue unless YOU too can make a financial commitment. SUFFER is SUFFERing too. I sincerely feel that we can survive this though and stop human formaldehyde poisoning if you will continue your support, both moral sup- port and financial support. Please dig deeper into your packets, skip a might cut, ask your friends/relatives to donate funds (also your attorney/physician), just please do what ever you nust to keep SUFFER alive. Thank you for your understanding and hopefully your immediate, continued support. Sinc el )~LfI00 4W4tI-.1'tflU9~ Iflow. Shirley Ashley 605-778-6716 *SOUIN DAKOTA SUFFER COORDINATOR 5102, Ron 48 KiAball, SD 07350 Clarence F. Ueckert 713-342-5830 aTEXAS SUFFER COORDINATOR 1123 7th Street Rosenberg, TX 77471 Eileen Cole 200-941.2655 .WASHIHOTON SUFFER COORDINATOR 2424 South 260th, Space 07 Kent, WA 98031 Mary Kappos 715-425-1184 .WISCCRSIN SUFFER COORDINATOR Route 1, Box 197 Beldenville, WI 54003 If yew would like to becoo,e a state coordinator or assist ymar state coor- dinator please contact the National Coordinator. 36 *BOARD OF DIRECTORS, Joan Oien (see above) Steve Patterson 612-856-4283 18183, Box 241 Zimmerman, RD 55380 Connie Serecek (see above) Judith Ulseth 612-888-8297 8807 Penn Glen Place Minneapolis, RD 55431 Mike Young 241 S. Cleveland, Suite C2 St. Paul, RD 55105 SMEDICAL RESEARCOER: Carol Palmero P.O. Box 1159 Bristol, Consectiout 06016 *CONSULTING A1'rCRNEY, Marc G. Kurzean 612-333-4403 601 West Butler Square Minneapolis, RD 50403 *ADVISORY BOARD: Professor Peter A. Breyaae Seattle, Washington STAIX SUFFER COORDINATORS: (alphabetical by state) Dan Devlin 002-971-5900 *ARIZONA SUFFER COORDICATOR 4848 East Tierra Buena Scottsdale, AZ 80204 Sheila Asses 415-828-1472 * CALIFORNIA SUFFER COORDINATOR 6422 Cypress Court Dublin, CA 9/R66 Harvey Priohett 303-532-2324 *CCLORADO SUFFER COORDINATOR 2700 Meining Rood Berthond, CO 80513 Al Palmero *CONNECTICUT SUFFER COORDINATOR P.O. Box 1159 Bristol, CT 06010 John Snyder 302-764-6229 *DELAWARE SUFFER COORDINATOR 411 Wilson Road Wilmington, DE 19003 Phyllis M. Wilde 904-893-0554 *FLORIDA SUFFER COORDINATOR 2990 Bayshare Drive Tallahassee, FL 32308 Jean Rrcaon 219-483-6891 *INDIANA SUFFER COORDINATOR 608 Elmer Avenue Fort Wayne, IN 46808 Charolotte Scott 600-437-7091 *KENTUCKY SUFFER COORDINATOR 142 Joes Creek Road Pikeville, KY 41501 Mickie Moore 301-252-1100 *IARYLAND SUFFER COORDINATOR 12 Nsrthwood Drive Timonium, 500 21093 David DeCoursey 617-201-3754 *MASSACHUSETTS SUFFER COORDINATOR 137 Wheeler Street Gloucester, MA 01930 Connie Sereeek 612-448-5441 *MINNESOTA SUFFER COORDINATOR jOllA, Box l4OC Wacon.ia, RD 05307 Helen Shackelford 816-869-3443 *8(LSSOURI SUFFER COORDINATOR 1001, Box 112 Lsteur, Missouri 64700 Mesa Sprague 406-620-7043 *MONTANA SUFFER COORDINATOR 5102, Box 1480 Laurel, Off R9O44 Mona Sprague 308-754-4901 *NEBRASKA SUFFER COORDINATOR RR1, Box 113 St. Paul, NB 68873 Peter Cooper 315-376-7959 O5EW YORK SUFFER COORDINATOR 0484 Ikinity Avenue Lowville, NY 13367 Sharon Anderson 701-235-3640 *NORIN DAKOTA SUFFER COORDINATOR 2320 20th Avenue South Fargo, ND 58103 Marie Vans 216-769-2262 SCIOIO SUFFER COORDINATOR 6260 Mud Lake Road Creston, OR 44217 INaooi Halley 503-876-5294 OREGON SUFFER COORDINATOR RR2, Box 58 Willamina, OR 97396 Donna Woods 412-033-2822 *PSSDOLVANIA SUFFER COORDINATOR BR2, Box 326 New Will~nington, PA 10142 PAGENO="0041" 37 FORMALDEHYDE LITIGATION GROUP - - - MEMBERSHIP AND REFERRAL POLICY. The Litigstios Group receives inquiries from individuals, attorneys, physicians sad others seeking names - of attorneys in their area who can prosecute a formaldehyde claim. It is the policy of the Litigation Group to forward names, addresses and telephone numbers of attorneys is the Litigation Group is the area is question. It is UP to the sttorneyo cuntooted to dotormine whether to take the case sod sake fee arrangements with the i,,, SAN FRANCISCO CONFERENCE On July 28, 1981, the first formal meeting of the Formaldehyde Litigation Group was held st the ATLt (American Itial Lawyers Association) `715~~ sonvestics in San Francisco. The mactin gwas attended by approximately 4G attorneys, `~ ~ evenly divided between Litigation Group meebera and other interested attorneys. `~o~goii'i ~` S. Ernoke Taylor, Esq., of Port Angeles, Washingtos discussed his recant HR66,RGO jury award on behalf of a woman who developed chronic asthma as a result of an eight week so- posure period in a new mobile home. The suit was brought against the manufacturer, Fleetwood Homes of Washington, the retailer and component part manufacturers Willamette Industries, Inc., and Van Ply, Inc.. The jury returned a verdict against Fleatwood Homes, the namufacturer and found the other defendants not responsible for the plaintiff's injuries. Mr. Taylor talked to jurors after the verdict. They felt the most compelling theory against the defendants was their failure to warn. The defense attempted to demostrate that formaldehyde can be found everywhere. Tha contention was less compelling after Mr. Taylor's export testified that a test of the atmosphere outside the mobile home demonstrated no measurable level of formaldehyde. Litigation Group meehers should request a reading of the outside atmosphere near the affected residential unit from testing companies to ensure that a response to this defense theory will be available. WRITE TO CPSC AGAIN))) Woy is it that the CPSC Alert Sheet contain the namea and addreases of the Formaldehyde In- stitute, the National Association of Urea Foam Insulation Manufacturers, etc., but never include SUFFER' a name and address? Victima should be given a name and address that would help them. Right??? Write to CPSC, Washington, DC 20207 and ask them to release SUFFER's name and address to victims. While you're at it, the Formaldehyde Institute has insisted on a copy of every correusication CPSC has with anyone about formaldehyde, including a list of victim's names and addresses. I'm going to tell them not to release my name and addreases to any industry associated with formaldehyde. Judith Ulseth Assistant Editor CANCER CANCER CANCER CANCER CANCER CANCER CANCER CANCER Os January 13, 1981 the U.S. Consumer Product Safety Coosmiasion (CPSC) voted to propose a ban on sales of urea formaldehyde foam insulation (ig'FI) because of the numerous health complaints they have received. Reported health problems from exposure to the formaldehyde fumes emitted by the insulatias have included' severe breathisg difficulties, eye irritation and impaired vision, rashes, chronic headaches, nausea and vomitisg, swollen glands and "mono" symptoms, heart palpitatioss and chest pains, inaseasia and irritability, swollen joists, "colds" and flu-like symptoma, fever and chills, neurological disorders, lupus syndrome and sun sensitivity, unconsciousness, cxsoer and death. The Coemiasiss's decision was made after the publication of the results of the cancer study sponsored by the formalde- hyde industry. Four species of asimala (rats, mice, rabbits and guinea pigs) were tested at 15 PPM or less of form- aldehyde. (These are the same levels that have been found in some homes with urea-formaldehyde foam insulation. Is fact some homes have had eves higher levels.) Formaldehyde produced canoera in 45% of all the animals tested. Houever, almost 100% of the rats tested ended up with exnoor of the respiratory cyst em according to a CPSC scientist. We believe in time it will be shown that formaldehyde is a major cause of the high lung cancer rate in this country and also the major lung carcinagen is cigarette smoke. (There are 40 PPM of formaldehyde is cigarette smoke--see TEG, June 1980.) Another : :2es not been test because attention. ~ ~ed~g attacked and killed each other. One of the serious can- sequences of formaldehyde is its effect on the central nervous \j) ~çs~5, ~ system causing extreme irritability, insomnia, confusion, loss of memory, ~ ~ asxiety, depression and "n~ouamass". Could formaldehyde be the underlying cause resulting in so many trasquilizers being presoriked in this country??? On January 14, 1981 state health, enviroomental and consumer protection officials proposed legislation for a Conseotiout ban of UPFI in case the federal effort fails (see Cosneotiout Update). In the Januao'y 16, 1981 issue of "The Journal of the American Medical Association" (JAMA(, there appeared a major article on the toxicology of UFFI by three doctors from the University of Colorado Health Sciesoes School of Medicise. The doctors cosoluded that "the risks of UFFI greatly esaeed any potential benefits." The Federal Panel an Formaldehyde, a group of seventeen governmental scientists working together Investigating the chem- ical' a toxicity, stated that "it is prudent to regard formaldehyde as posisg a carcinogenic risk to humasa." Carol Palsero Medical Researcher 3 PAGENO="0042" Q a, A These are excerpts from letters written by Susan Warder CANADIAN abou~ed:: S TO R'( coping with formaldehyde. ~ My daughter's future health and professional studies have apparently been gravely jeopardized by her chronic exposure to fornaldehyde gas. After assuning a normal workload as a nester of the National Arts Centre Orchestra during the summer of 1980, Marie began studying at the University of Toronto, in the "closed environment" Edward Johnsos Ouilding, which houses the Faculty of Music. There, when ahe is inside, her fossaldehyde-related symp- toss reappear. She suffers difficulty in breathing, nausea, dicciness, extreme pallor, headaches, and exhaustion, and nay be obliged to with-draw fran the university, as a result. According to many allergists, including the well knows Or. Marshal Mandell, M.D., of Norwalk, Cosnecticut; Or. 1. 0. MacLesnan, of Mactitan, Ontario, whose research is widely usosn in Canada; and many other specialists in chemical allergesx, Marie has probably developed a hypersensitivity to forsaldehyde, certain other caldehydes~~, and perhaps other chemical irritants. "She now cannot tolerate tobacco smoke, whereas, although sever a smoker, she could toler- ate ssoking by others until this year. (Tobacco smoke, of course, costains 40 PPM formaldehyde--see ITO, Vol. 1, No. 1, June 1980.) October 26, 1980 when our daughter Marie lived sway from hone en a one-week trial, is November 1979, her nausea and headaches subsided. After the foam was removed she improved iemedtstely, although it tank her approximately three months to regain the good health she consistantly enjoyed before the foam was put is our hone, and to which her ex- cellent school attendance, fine academic record, end full extra-curricular program attest. In all, she was unable to live a normally active life for approximately ten months Thorough clinical tests end consultations with various specialists, ordered by both Dr. Gilka and Or. Byron Hyde, revealed no organically-related cause of illness NOVEINER 8, 1980 In early Septesbar, 1980, when Marie left hcaee for Toronto, her energy levels were high, her coulour usa goad, she apparently needed only eight to nine hours' sleep sightly, and the e~yasthenic' ayndrome which had begun to develope in her eyelids early in 1979, shortly after the foam was installed, had almost disappeared. Is brief, she had set considerable demands on her physical and mental resources all sacrseer, including two months cf work as a eeeiser of the National Arts Centre Orchestra durimg their opera season. She was in fine health and working hard. Pro- fessor I. Fenyves, of the Faculty of Music of the University of Toronto, sham Marie and I saw in August, 1980, can con- firm this. When I next saw Marie in Toronto a month later (September 27-28, 1980) I was aghast. She looked almost es ill, pale and exhausted as she had during the winter and fall months of 1979, the period when, according to the Wornock-Heraey'e tests done on the air in cur home and all other indications, she was suffering foam the adverse effects of formaldehyde gsa. After one masith of living in a gas heated apartment with a gas stave, her pallor, fatigue, tension, and pronounc- ed eyasthenic syndrome in the eyelids were sstaexsding. FEBRUeRY 24, 1981 I as writing to request that the leave without pay which was authorized for se until March 2, be extended until March 30, 1981. Ocr daughter is still a virtual recluse in two races af our hose, dependent on Porafil formaldehyde filters. Furthersore, the Ontario Research Foundation has r~ssted that we consider vacating our house for a five-day testing period (at their expense) and we are hardpresaed to find accoesadatic,ns that op be able to tolerate. In brief, the various disensionx of Marie's handicap are sore complex than I had APRIL 27, 1981 Pr. Russell Mills, Editor, ~ Ottawa, Canada Dear Sir, Our federal goverssaent has just percanently banned urea formaldehyde foam insulation. Since it thus acknowledges the toxicity af the fsrealdehyde emitted by the foam, has can it continue ta delay in isposiag realistic nstianal standards for form- aldehyde in the air af office buildings and bases? Likewise, the goverrasent is aware that the east cce,son early syeptass of faresidahyde poisoning are drowsiness, ass- culer weakness, difficulty in concentrating, short-tare, sessary lass, headaches, various EENT disorders, etc.. Health and Welfare afficials also know that formaldehyde is a "sensitizer" chemical that can cake sassy of those exposed to it aabsequently usable to tolerate not only forealdehyde, but also numerous other chemicals found in tsp water, in- secticides, food preservatives and colourings, tobacco smoke, exhaust fumes, oil and gas combustion by-products, etc.. Why are they not informing the public cf these facts? My family and I were made sick for 11 months by UFFI. We had to resove it fros our wells. The producer and installer denied their responsibility end refused to coepensate us. The most distressing aspect of the sighteere, however, is the fact that op daughter is now one of the "chemically disabled", who, due to an initial poisoning by UFFI (or other foresldehyde.esjttjng products) oust now sac psorafil/charcoal filters and casks so as to control their "allergic" re- actiosa to chemicals normally found in sealed buildings, on city streets, and even in their hoses. In op daughter's case, leading allergists have advised that she most live in the country and resove all possible can-cede chemical tox- ins fros her environment, if she is to regain and saintain her health totally. Forealdehyde-induced illness has cede her lose twa years of university oredits toward her B.A.Music Degree is violin perforeance. HiM CAN OUR 800ERNMERT DENY ThAT PEOPLE ThUS DISABLED, AND ThEIR FAMILIES WHO ASSUME IHE FINANCIAL AND MORAL BURDENS VaLVED IN ThEIR CARE, DESERVE CCOVERSATION? IS OUR GOVERNMENT SO PROTECTIVE OP IHE FORM9LDERYDE INDUSTRY ThAT IT DARES TO IGNORE ThE MORAL, MATERIAL AND PHYSICAL DAMAGES SUFFERED BY ISlE VICTIMS OF A PRODECT ACCEPTED BY ThE Q5(C AND SOLD UNDER ERIP? Is their personal correspondence with ox this winter, the Hoasourable Minister of Health and Welfare and the Monaursble Minister of Cons,aser and Corporate Affairs did not even acknowledge that feet that ny letters to thee, contained requests for coepensatjon and the ather related questions raised here, either in The Citizen or in another printed osdia. o5'estheniceauseular weakness Susan Warder Sevard, SUFFER Member Wsrnock~Hersey tests-private testing coeaseny Judith Ula th As istant Edit ?*purefil formaldehyde filters=Decatuar, IL coepany PAGENO="0043" 39 A REVIVED S1DS `BRUCE SMALL book "Sunnyhill" As a sine month old child, her mother scooped her from Canadisn Bruce Small, who wrote the her bed and shook her until she began breathing again. (see ~ Vol. II, No. I & II, Februsry, 1981) and spoke A REVIVED 5105 (Sudden Infant Death Syndrome) BABY! to SUFFER and HEAL seekers in the Twin Cities areaslast Maroh, was recently named The Environmental consultant That Was cody the beginning of Mena's childhood illness- for the Canadian National Research Council. He will be es. As a young adult she was able to live almost like educating medical and other professionals on the hazards other young people, but again as she grew older her of formaldehyde used in building materisls. Canada health worsened. Rashes, dizoiness,and nausea is how banned UFFI based only on the United States cancer she reacts to the ordinary world of molds, perfumes, studies. They didn't even consider yet that formaldehyde petroleum products and formaldehyde, is a sensitioer. A recluse for two years now, she and Dave, her husband, have had a difficult time finding a hone that ian't C A L E N D A N is chemically saturated. The best place she has lived her old farm house in Nebraska. New homes are out of July `oi Litigation Group the question. San Francisco and New Orleans Recently Mona spent time in the environmental care unit Gct~be~ `RI ~ ~em~ars `RI in Denver,CO. She has found many products and habits i p 1 Civi Ct over the years that lessen her sensitivity and she is i t p 1 MO ouch improved. In May she was able to visit Minneepolis and speak at a SUFFER meeting an our Nebraska/Montana October `RI International Symposium on Indoor Air Coordinator. pollution, Health and Energy Conservation Aeherst, Massachusetts They are worm, informative, "talkin over the fence" kind of people. Dave is Mena's guardian and can tell Octeb `RI died. i t S ci she gets giddy that she's been fiddlin with the mews- h PA print too long or used the wrong kind of soap. Hers y, Noveeber `81 SUFFER Seminar Mesa welcomes calls and letters. 2nd Southdale Library Judith Ulseth 7:00PM Minneapolis, Ma Assistant Editor Novena~,er `RI SUFFER Seminar 7th & 8th Bloomington Energy Show Bloomington, RN EDEQI US OUT AT IDlE LIBRARY SUFFER hen heard from r~Publis~ersof S~aO~A~~ll NovecRer `RI ~ soon be listed in that reference book. Ask your library 23rd . ehy to keep our "formaldehyde flier" (see lEG, Feb. 1981)on 9.3~~N file so others can be educated en the hazards of form- `81 or `82 First Annual SUFFER Conference on Formaldehyde aldehyde. Minnesota issue. Addressyour1etterIettert0the0"~ March `81 First National Conference on Formaldehyde give your permission to print your letter along with 3rd & 4th Ball State iverz~t3' Illness y me. Muncie, Indiana STOP HUMOR FORMALDEHYDE POISONING, BAN FORMALDEHYDE! Attention: Shad Godish Join myself and a NY member, write this on all envelopes. "MOBILE HOIVIE SYNDROME" (~r~y in 1900 ou~ vacant mobile home was evicted From the mobile home court it has been situated on since it's delivery in May of 1978. Due to formaldehyde offgasaing the home has bean vacant since Febuary of 1979 when, on the advice of two physicians, we did not return home because of our infant daughter's poor health while living there. There- Removal of the home from the lot ie,oediately terminated our homeowner's value if vandalized or destroyed. And, fore, the hone would be worth zero dollars 70' mobile home? We allowed it where does one park an evicted and vacant 14' x to be reposseased after paying the payments for over 18 months while it Any repossessed home is available for ~ resale. Because of the health ailments I suffered by our family in the home ~ W and the continuing offgaasing of formalde- I troyedpubli ~ ~ui ~nd ed~hka~eedgan~h~ even order it d a mobile home has been femmally condeemed in this nation. Our decision to go beforeV or the county health board seemed the only logical route to take. Our law- suit ha be ong beg f 2 y a Mike and Nancy Clay PAGENO="0044" 40 - UPDATES - * c0NNEcTIcU'r TJPDATE Gao. O'Neill signed a bill Some 2, 1981 banning the installation of UFFI in any building, effective immediately. The Coesnittee vote in the House was 16 yea and 0 nay. Connecticut is the second stste to ban UFFI, Massachusetts was the first. *MINNESOTA UPDATE The new bill, which would hove set s level of 0.1 PPM, was tabled and killed during the House Health and Welfare sub-committee hearing on April 2nd, 1981. The industry out numbered us 2 to 1 though SUFFER centers spent hours on the phone notifying people about the hearing. Industry's ,nsin points of defense were: I. A standard of 0.1 is incapable of being net because it costs (do you be- lieve this!) $600.00 to teat air and $1000.00 to determine ambient air. 2. The coat of building a mobile home with a 0.1 PPM standard would add $2500.00 to the price of the home. (How many of you victima would rather pay the $2500.00 than yam medical bills or the coat of moving and losing your entire home?) 3. Industry belimveo standards en the products themaelves should be utilized. In fact they said auth a schedule of standards wan being set up and would be publicized in two weeks! That waa the point at which the bill was tabled to wait for these "self imposed product standarda" to be announced in two weeks. The 1981 session of legislature ended and not one ward has been heard from the industry about the stand- ards. The following statement is given to some Minnesota consumers who buy particle board, plywood paneling, etc. containing formaldehyde: Dear O.stomer: The Minnmsota State Legislature paused a law effective January 1, 1981, relating to those building materials manu- factured with binders or adhemiven containing arms-formaldehyde. Spocific building produeta which are apt to contain this substance are psrticleboard, fiberboard, and hardwood plywood. After inatellation and/ar over a long period of time, "free farmaldehyde" may be emitted from these products into the indoor air of a structure and be potentially harmful. The law states that amy Minnesota purchaser of these producta (or a housing `omit in which they are incorporated) be provided with the following written disclosure from the manu- facturer: °WARNI}13, ThIS PRODOUT (OR HOUSIOU UNIT) CONTAINS TEE CIAE$IICOL FORMALDEHYDE. FOR SONS PEOPLE FORMALDEHYDE MAY CAUSE HEALTh PROBLEMS SUI4 AS IRRITATION OF TEE EYES, NOSE AND INSOAT: COU?HING, HEADAGOES, SHORTNESS OF BREATh, OR ES66ST OR STOMACH PAINS. CHILDREN UNDER ThE AGE OF IWO, 51DERLY PEOPLE WITh BREAThING PROBLEMS OR PEOPLE WITh ALLERGIES MAY HAVE MIRE SERIOUS DIFFICULTIES. IF YOU HAVE IJESTIONS ABOUT PROBLEMS YOU MAY HAVE WITh FORMALDEHYDE, CONSULT A DOCTOR.' Sane lumbezyarda, unhappily reported by Pay Smock, atacp the warning on the products with a tiny rubber stamp. Another, my sources tell me, is fed up with government regulations, and has posted his own version, hand written en a 2' x 3' sign over his cash register reading as follows: "NOIECE--Anytjaing you buy here may be hazardous to your health. See your doctor or ask us en any potential hazard--wood splinters, nails, hammers, plywood--you mama it. Ask about government regulations regarding disclosure." The Minnesota Department of Health, which is in charge of setting new home formaldehyde standards has proposed an am- bient level of 0.40 PPM. They invited public comment until June 20, 1981 (while my letter was dated May 28, 1981, allowing enough time for response, it was not postearked until June 12, 1981--I wonder how any victims of formalde- hyde, people who have had to evacuate their homes, live in tents, move in with relatives, etc., received their notice in time to respond! Also, I have spoken to victima who received no notice.) and will gather those commenta into view far a public hearing before they adopt the standard. SUFFER cannot support a 0.40 PPM standard, and instead oust ask for a complete ban. To support a certain level, even below 0.40 PPM is impossible since no level has been found to be safe. Infect, evidence as to formaldehyde toxic, cancinogemic and mutagenic capabilities continues to grow. Address your comments to Ms. Laura Oetman, Section of Health Risk Asaeas~t, P16 Dept. of Health, Divialom sf ERvironmental Health, 717 Delaware St. S.E., Mimaeapolis, IN 55440. Also ask her to inform you of the hearings so that you may attend. *CHIO UPDATE Cincinnati banned UFFI effective July 1, 1981. OREGON UPDATE House Bill #2899, sponsored by Representative neuman of the Oregon Legislative Assembly, was overwhelmingly passed in the House only to be stamped on when presented to the Senate. Professor Peter A. Breysse of the University of Washington and Dr. Corn of Portland, Oregon provided expert testimony for the Bill. The Bill wonld have called for a ban en UFFI and labeling of building products containing formaldehyde. Rep. tmumam's toll free num- ber is 800-452-0290. Also, Senator Packwood is influential in C~eas es chair,ean of the Commerce Committee. You can write to him at 145 Russell Building, Washington, DC 20510. *NEW YORK State Asaembly,ts~ Jose Smrrano, Chairmen, of the Assembly Cosasumer Affairs Committee, proposed action en UFFI in the form of either permanent or temporary ban, or an amended warning notice to cite the cancer risks alas. At the May 4th Statceasembly Hearing, the eanufeub~era lobbied against a ban, blaming the problem on same of the installers. Also, Martin B. Weigand, President of North Country Insulation, Inc., whose company installed Peter Cooper's (our New York Csordinator) UBTI, contends that the CPSC watchword is "career advancem~t" not "consumer protection'. Weigend stated his motivation for supporting UFFI is not financial but moral belief in the safety of the product he sells. *TEXAS UPDATE Effective September 1, 1981, the law requires that any retailer or manufacturer who sells mobile home must include a warning about formaldehyde gas. Call U12-475-)7I2 if you have questisnu concerning the law. PAGENO="0045" 41 PROFESSOR PETER A. EREYSSE, of SUFFER0 advisory board and Associate Professor of the Department of Environmental Health at the University of Washington, wrote the following letter to the Minnesota Department of Health. SUFFER suggests that you cay want to COPY this letter and share it with your congressmen, health department, news media, etc.. TO WHOM IT MAY CONCERN: I have reviewed the proposedFormaldehyde Regulation and wish to cake the following constants: 1. There is no doubt that the ambient indoor level of 0.4 ppm is ouch too high. First of all, the National ACaden5' of Science in a report to the Consumer Product Safety Commission states that there is no threshold for irritation and no matter how low the formaldehyde concentration, some individuals will respond adversely. Furthermore, The Academy recoumended that indoor level for formaldehyde be kept as low as practical. Recently the National Institute of Occupational Safety and Health (NIOSH) published a document dealing with the can- cer potential of formsldehyde as the result of two different animal studies. SlOSH han also recommended that the Permissible Exposure Limit (PEL) be lowered to I ppm with an action level of 0.5 ppm based on a 30-minute sample. Medical exams would start at the action level. The PER is defined as the atmospheric concentration of contaminants that workers can be exposed to for an 8 to 10 hour work dsy, 40-hour work week throughout the work life without resulting in an appreciable heslth danage. The PER is not an absolutely safe value. People ony experience discomfort even below the PER, or they may develop an aggra- vation of a pre-existing condition and some nay even experience an industrial disease at or below the PER. The PER has been established based on the best available information. I have calculsted the amount of formaldehyde absorbed by a worker exposed to 1 ppm for a 40-hour work week breathing at the rate of 15 liters of air per minute. It equals 45 mg per weak. A housewife with small children to care for may well spend an averege of 20 hours per day in home for a dull week. Her absorbed done of formaldehyde at a breathing rate averaging 12 1pm and at a level of 0.4 ppm would be 50.4mg per week. Of course, a very young infant and zany elderly and disabled will also spend an apprecialbe amount of time in the home and be exposed to comparable amounts. 2. A number of countries have established formaldehyde limits for homes. Germany and Holland utilize 0.1 ppm. Even this low level will not adequately protect those allergic to or those highly sensitive to formaldehyde. 3. The American industrial Hygiene Association in their Conmunity Air Enality Guides recommended that formaldehyde concentrations be held under 0.1 ppm. (September-October, 1968). Finally, the movement toward tightening structures for energy conservation will. likely complicate the indoor air quality. There are a nutber of homes in the Seattle area with urea foam insulation in which no problems were ex- perienoed until storm doors and windows were added reducing the leakage of outside air. A question that could be raised regarding a 0.4 ppm indoor limit for formaldehyde concerns the problem of a new home with a 0.4 ppm of formal- dehyde that is subsequently tightened. No doubt that the levels will go higher. Hen would this be handled under the regulation? The following are comments directed toward certain provisions of the standard: Testing Conditions E-1 - If there in no humidity control, how can one assure that the humidity will be between 40 to 60%. c-I-C - We have monitored approximately 700 homes and have concluded that it is desirable to have window and doors closed for at least 18 hours in order for the indoor environment to stablice. One hour is not enough tine. E-4 - Requires installer of foam insulation to monitor, no provisions however for hoses with only particle- board, such as mobile hones. The most important source of formaldehyde in hones includes both foam insulation and particleboard. We have viewed 5 hoses in which the foam insulation has been removed and in every instance there were appreciable voids and shrinkage such thst 40 to 70% of the insulation value has been reduced. We have also had calls from 6 other home owners reporting similar results. It appears that urea formaldehyde foam dome not provide effective in- sulation. Partielmbosrd is probably the most significant and dangerous source of formaldehyde and will release this chemical for zany years. Of the 450 mobile homes that we have monitored, some as old as 12 years, still retain neasureeble levels of fsrmaldehyde. Recently a court in Port Angeles, Washington awarded a resident of a mobile home 0566,500.00 for damages. Other court cases throughout the United States are pending. It seems inconsistent that a state health depertment would draft legislation allowing the introduction of a hazardous chemical into the home environment at levels many conxider dangerous. The most effective way to control this problem would be to ban both urea formaldehyde foam insulation and particleboard rather than to attempt to establish a standard that is excessive and will be difficult if not impossible to enforce. PAGENO="0046" I, ~ ! ~:~~IL II II I PAGENO="0047" 43 is FORMALDEHYDE POISONING YOU AND YOUR HOME? YOU LIVE/WORK IN A NEW HOME/BOJIRDING OR IN A MOBIRE HOME/UNIT OR IF YOUR HOME/WORK ENVIRONMENT CONTAINS UREA FORMALDEHYDE FOAM INSULATION (UFFI) PARTICLE BOARD PANELING PLYWOOD CARPETING OR IF YOUR OCCUPATION ERPOSES YOU TO PRODUCTS CONTAINING FORMALDEHYDE, THAN: YOU TOO MAY BE A VICTIM OF FORMALDEHYDE POISONING When you first learn that formaldehyde has taken over your home, you probably feel like the only person in this world that this has happened to. WRONG! Hundreds and hundreds of people from the United States and Canada hove con- tacted national SUFFER headquarters. Rational SUFFER responds to between 2 and IS phone calls and letters daily. We feel that everyone is affected by formaldehyde to some degree, they just may not be aware of it yet. YET is the key word. Will it happen to them nest week or will it take another year or two? It took one family two years to learn that formaldehyde was in their home. Another family lived in their home for almost seven years before they too learned thot formaldehyde had contaminated their home and their bodies. When will you stow it has happened to you too? YOU CAN BE AFFECTED WITHOUT EVEN KNOWING YOU ARE EARAURES CONGESTION DEPRESSION NAUSEA, VSRDTING SORE, STREP THROAT COUGHING ESAIAUSTION IRRITABILITY FLU-LIKE SYMPTOMS RUNNY, BLOODY NOSE p5t . DIARRHEA SKIN RASH RUNNY EYES ASTHMA-LIKE SYMPTOMS HEADACHES MANY, MANY OTHERS AS WELL AS POTENTIALLY CAUSING INFANT DEALTHS COlDS) AND CANCER EVERYONE IS AFFECTED TO SOME DEGREE WAY DOES SUFFER NEED YOU??? WE HEED YOUR FINANCIAL SUPPORT AS WOOL AS YOUR RORAL SUPPORT. IF YOU HAVE FOUND SUFFER TO BE HELPFUL VIA TELEPHONE PERSONAL LETTER NEWSLETTER MEETING ETC. PLEASE CONSIDER THE COST TO US IN OBTAINING THAT USEFUL INFORMATION AND THE TIME THOSE VOLUNTEERS ARE SPENDING WITH YOU. SUFFER CANNOT CONTINUE HELPINGYOUANDOYNERSWITHOUTMONEYTOPAYTHEBOOLS. SUFFER IS EXPERIENCING FINANCIAL DISASTER!!! year ego a eossitaeA see sods to pailieh as year 14 i.siea) of tesul.tnrre. OSat year As: esded. 5GFftt hue masereis eoeteotu weal tie said, 5: hear ha helpful se bane been bit east e.nllie: peso they onset effoed te debt, O~ eel yer dollars ease If tbeee 5. to be .oetberseseletteri:eaed. H yea eon find a say 5o leAp eapyct a: a, sill eoetloa, pailleAieu ste Poesceeeetel laerdiee. Os nape so blelad, articles relating to: 4.45. Save Us Pram Formaldehyde Environmental Repereuusiane SEND IO2IBERSHIF DONATION TO: SUFFER, INC., RRIA, BOX 148C, WACONIA, 141 55387 (612) 448-5441 0 RN.CO enclosed for iasue #1, June ~ $0.00 enclosed for issues #2 & 3 ~ $0.00 enclosed for issue #4, October 1980. Includes: SUFFER's Victim (coobined), Febuary 1981. Includes: 1981. Includes: SUFFER's Incident Health Questionnaire (4 pgs. of CLIT Report on Formaldehyde am a Report (share with attorney/physician! vital data including health aypp- Carcinogen, Formaldehyde and SODS, teacher/SUFFER), Mibile Hone Condersta- toma, e tenaive list of products Has Your Mobile Home been Resold, tAos, Legal Ledger (Litigation Group i containing formaldehyde & "MediG Testing levels, Flier (pest me), HID1O Court Case), Altercate Noons for farm- Allsrt", neurologic info, and Your Being. eldehyde, Prof. Breyase'a Review. CURRENT NRII5LETTER (4 ISSUES YEARLY) AND MDCOERSIOOP DONATION INFORMATION SUFFER meebers are helped by star ________________________________- ing information, if you prefer cc- name maiming anonymous check box. _____________________________ ~j Victims ask SUFFER for a list of title SUFFER meeebers who are medical! _____________________________________ legal professionals who are stew- address ledgeable about formaldehyde. ___________________________________ Check box if you would like to be city/state/zip included & send letter stating _________________________________ expertise, area code/ttiepO:one~f r~~\ Individual/family $20.00 ~ Professionals $00.00 ~ Sponsorship $100.00 or sore Note: $5.00 applies if current meedeership donation is received within 2 weeks of notification. ~ I'd like to be a SUFFER Coordinator for e~r state. ~ I'd like to assist my etate SUFFER Coordinator, PAGENO="0048" MF[)IA FVE~1S ....Followisg is a list of articles published or programs broadcast which deal with formaldehyde. You may want to srite requesting a copy of the article/transcript. Mention in your letter that yen are a victim of formaldehyde and a SUFFER member. JAMA (Journal of tho American Medioal Association), January 16, 1901. Environnent and Bahovior, by The Center for Science in the Public Intereat. Membership $20, contact Kirk Johnson, 1705 South St., NW, Washintos, DC, 20009. May 1901, Vol. 1, No. 2. gben Business, 1515 Broadway, New York, NY 10030. ç~ress Watcher, March/April 1981. 215 Penn. Ave., SE Washington, DC 20003. Send letters to the Editor re- garding The Clean Air Act. Natural Resources Notes, #1 & #2, Formaldehyde. Dept. Natural Resources, Ball State University, Muncie, IN 47306. Self addressed stamped envelope. °Ek,iscy" or NBC TV, program scheduled for fall 1981. Maurice Klugman, c/a Univernsl City, CA 91608. "Bitter Harvest", May 18, 1981. Ron Heward or NBC TV William Sohuller Agency, 9110 Sunset Bivd., Los Angeles, CA 99069. NIOSH CURRENT INTELLIGENCE BULLETIN # 34, April 15, 1981 Publications Dissemination, DTS, Notional Institute for Occupational Safety and Health, 4676 Columbia Parkway, Cincinnati, OH 45226. Consumer Federation of America, Suite 901, 1012 14th St. NW, Washington, DC 2000), (202) 737-3732. Federal Register, Feb. 5, 1981, CPSC, Superintendent of Documents, US 5cc. Printing Office, Washington, DC 20402. Federal Register, write CPSC for the copy in which HOD is requesting comment on nubile home regulation. "You Asked For It", Box 710, Hollywood, CA 90028. Let then (omen you'd like to vinit, via IV, a prescription home for the chemically sensitive. Travel & Holiday, Travel Building, Floral Pork, NY 11001 May 1981, Vol. 155, No. N. People Magaoine, January 26, 1981, Dr. Alfred Zaeon. (Conk, from next coluon) Out cries were heard and two hearings were held, but they could only find that Infante used government paper to ~ pass on whathe con- sidered to be pertinen data. Walker also testified that ~go~ Auchter ordered him to fire ENVIRONMENTAL Infante, whose job GUARDIAN was then rein- IS PUBLISHED BY SUFFER AT stated. EDITOR, CONNIE SHOECEK ASSISTANT EDITORS: PATSY ALFORD JUDITH ULSESU SKEICHES: SCOT SINNER 44 BUDGET CUTS TO CONSUMER PROTECTION AGENCIES (CPSC & EPA) MAY CAUSE MORE HARDSHIP TO CONSUMERS THAN UNSUBLOYMENT ABS HIGH INTEREST RATES The Consumer Product Safety Commission, the only federal agency with jurisdic- tics over chronic hazards in consumer products, has had the deepest budget cuts of any federal regulutory a- gescy. Cuts have stopped o dozen research projects and cloned 8 of 13 regional offices. Nancy Harvey Stmorta, newly appointed chaiman, claien she is cutting only the fat from the budget but she just remodeled her office at a cost of 08000.00. At a recent hearing the staff announced the final report on formaldehyde as a carcinogen would not be issued for 130 more days. The formaldehyde industry opposed the em- tention "because they're losing money; their customers will be scared off until the issue is decided". The En- virosz,ental Protection Agency's staff and operating bud- get will be cut in half over the next 2 years. That will drop the number of staff by 30.8%. What are the results? The drafted proposals would weaken the Clean Air Act of 1970. Basically the proposal is to drop restrictions where dirty air has not improved and provide special pro- tection for areas of clean air. New administrator Anne Gorouch, cuot also find funds for the sewer cosstructiion grants program for cleaning up toxic wastes. Immediate action on formaldehyde sasoaroinogen has bees discounted. The reasoning is cancer wan caused in rate at ouch high Novels of formaldehyde (iN PPM was measured in some UFFI homes) and under ouch long exposure times (sin hours a day, 5 days a week rats were subjected to formaldehyde. How many hours and days are mothers end children subjected to formaldehyde vepors in their homesl) In order to justify the switch, EPA held a series of "re- view meetings" with industry consultants, leaving out the agency's mom cancer specialists. The other team of toxicologist responsible for ouch of the research was cc- cluded also. Head of the EPA carcinogen panel, Dr. Roy Albert hasresigned because of the exclusion. Former Director of The Rational Cancer Institute, Dr. Arthur C. Upton, is worried "If the evidence is ignored, it would mean that no agent could be regarded as carcinogenic in the absence of positive evidence of canner in humans. At the same time the schedule for Congreas to regulate chemicals will double is the early 90's and double again at the end of the decade. For weeks, top cancer specialist, Peter F. Infante, didn't )osow if he would be dinmkased from his job for OSHA. The problems began when Assistant Sec. of Labor Thorne 0. Aucter backed out of distributing formaldehyde warning bulletins. Infante wrote a letter about formaldehyde to a World Health Organization suing government stationary and enclosing a NIOSHE warning bulletin. Somehow the in- dustry got a hold of that letter and complained to the heads of OSQ(A. Diemissal action was initiated and signed by Bailua Walker, then Director of Health Standards. (Cont. previous column.) THE CONTENTS DO NOT NECESSARILY REFLECT THE VIEWS AND POLICIES OF SUFFER OR ITS ADVISORY BOARD, NOR DOES MENTION OF PRODNCTS CONSTITUTE ENSORSENENT OR RECONNENDATION FOR USE. SUFFER BR IA, BOX 148C WACONIA, MN 55387 ADDRESS CORRECTION REOHESTED .5:, FIRST ClASS PAGENO="0049" 45 IHE S AVE us F F ORMALDEHYDE E NVIRON MENTAL R EPERCUSSIONS VOL. U, NO. I & II FEBRUARY, 1981 97-153 O-82----4 PAGENO="0050" 46 Board of Directors: Steve -Patterson (612-856-4283) 883, Box 241 Zinocersan, MN 55398 Connie Sereoek (612-442-4665) BB1A, Box hOC Waoonia, MN 55387 Mike Young 241 S. Cleveland, SaNte C2 St. Paul, MN 55105 Consulting Attorney: More G. Eorzsan (612-333-4403) 601 West Boiler Iqaare Minneapolis, MN 55403 National Headquarters: Connie loreoek (612-442-4665) RATIONBL SUPPER COORDINATOR BRUA, Boo hOC Waoonla, MN 55387 Ann Miller (612-597-3572) ASSISTING NATIONAL C0001INATOR 002, Boo 2440 Anon, MR 56310 Joan Oion (612-436-7293) ASSISTING NATIONAL COCHDINATOO 12444 PartnidEc Court Stilleator, MN 55082 Bistory: SIPPER is a grancroots-type organication established by concerned persons e ho have suffered from the health, emotional seA finauoial effects of lining and socking in areas contaminated by chemi- cal mubstasoes, the cost prevalent icing formaldehyde. Activities: 1) To provide information and educa- tional material to the public about pamoiblc hacards, remedies and safeguards involving chemi- cals used in construction and rmmodeliog of hoce and sunk areas. 2) To aid families and individuals eho hove in fact suffered from the effeots of chemical poisoning enpeolahlyfromsouroes over cbich they havo no control. Purpone: To promote the general celfare of the public and prcnerve the right of the In- dividual to live and cork in an environ- ment free froc hazards produced by the use of checicals chich can be dotrimen- tal to mis/icr general health and cell- being. COORDINATORS Dam Devlin 602-971-5900 ARIZONA SUPPER COORDINATOR 4040 East Tierra Buena Scottsdale, AZ 05254 Sheila Adams 415-828-1472 CALI000NIA SlIPPER COORDINATOR 8422 Cyprecc Court Dublin, CA 94586 Al Palmero CONNECTICUT SUFFER COORDINATOR P.O. Boo 1159 Brimtol, CT 06016 John Snyder 302-764-6229 DELAWARE SUPPER COORDINATOR 411 Wilson Road Wileingtnn, DC 19803 Jcanette Seller 404-983-3705 GEORGIA SUPPER COORDINATOR P.O. Boo 315 Ciermout, CA 30527 Daniel A. Connors 200-524-1521 IDAHO SUPPER COORDINATOR 1350 Shipp A venue Idaho Pulls, ID 83401 Eunice B. MoCue 312-746-8792 ILLINOIS SUPPER COORDINATOR 1916 Boreb lion, IL 60099 Jean Brown 219-483-6891 INDIANA SUPPER COORDINATOR 608 Elmer A venue Port Wayne, IN Niokie Moore 301-252-1150 MARYlAND SUPPER COORDINATOR 12 Northomod Delve Timosium, MR 2lR93 David loCourmey 617-201-3754 MASSACHUSEITS SUPPER C0000INATOR 137 Wheeler Street Oloucester, MA 01930 Cumuic Ssreooh 612-442-4665 MINNESOTA SUPPER COORDINATOR 8018, Soc 14RC Waconia, MN 55387 Menu Sprague 406-628-7643 MONTANA SUPPER COOERINATOR 002, Pox 1480 Laurel, MT 59044 Mesa Sprague 300-754-4901 NEBRASKA SUPPER COERDINATOR 601, Box lL3 St Poul, RB 68873 John W. McKee 609-263-2844 NEW JERSEY SUPPER COORDINATOR 11 50th Street Sea Isle City, NJ 08243 Peter Cooper 315-376-7959 HEW YORE SUPPER COORDINATOR 5484 Trisity A venue Lmuville, RU 13367 Marie Vana 216-769-2262 0100 SUPPER COERSINATOR 6265 Mad Sake Road Creuton, ER 44217 Naomi Eelley 503-876-5294 OBERON SUPPER COORDINATOR RR2, Box 58 Willamlca, OR 97396 Donna Woods 412-533-2822 PENNSYLVANIA SUPPER COORDINATOR 002, Box 326 Nez Wilmington, PA 16142 Shirley Ashley 605-778-6716 500TR DAKOTA SUPPER COURDIBATOR 002, Ocx 48 Kiciall, 50 57355 Clarance P. Ocohert 713-342-5835 TEIRS SUPPER COORDINATOR 1123 7th Street Rosenberg, TI 77471 Eileen Cole 206-941-2655 WASHINCTON SUPPER COUERINATOR 2424 South 260th, Space 57 Eent, WA 90031 Mary Eappes 715-425-1184 WISCONSIN SUPPER COORDINATOR Route 1, Boo 197 Beldenville, WI 54003 Of you uould like to become a state smordlnatsr orasmist your state 00cr- dinotor please contact the National Coordinators, QUESTIONNAIRE The June 1980 issue of TIOR ENVIRONMENTAL GUARDIAS contained a questionnaire seek- ing information on dealers, masufactur- ens, phyniohass, attorsmys, helath symp- toms, etc This information helpm lOPPER to help you and other victims. If you have sot yet mompleted this questionnaire, please do so as soon as possible and re- turn it. Also, if there are other qoes- tions you feel should be listed, ploase let us kooc. Ql9Rl, Waconia, Minnesota PAGENO="0051" Dear Readers, SUFFER reoeived a tremendous response to the June 1980 issue of THE ENVIRONMERTAL GUARDIAN SUFFER's first neenletter. I have bees inundated with letters and phone ealls free across the United States, oith a few sore coming free neighboring Canada. While we real- ized the formaldehyde problem sos widespread, we didn't realize the. magnitude of assistance we needed to offer. It seems so many families are affected by formaldehyde, they just didn't know what it was before now, You can't see formaldehyde in the air. Must people are not educated to the hazards of breathing formaldehyde, so they dent know to look at their en- vironment as a source of their health problems. In addition to the formaldehyde victims we Initially contacted we're also hearing from victims who have heard of SJJFFER via the media, colleagues, other or- ganizations, governmental agencies, formaldehyde fliers posted on local bulletin boards, cedical pm- fesmionals, attcrceys, friends and, yes, even employ- cow of the industry itwwlf. SUFFER in greatly respected by various governmental agencies nbc are concerned with the hazards of formaldehyde. I want to thank every one who resprnded to SUFFER/ THE ENVIRONMENTAL GUARDIAN. Many cf the pecpie we hward free have been uprooted free homes, drained f I- nancially and their health left in a state of ruin. While it is cc consolation tn know that it in happen- ing tonuwerous other victims It may help tc know that the other victims understand the nightmare you are living daily. There are also professional seho are learning and researching this prchiem. Many cf the people ohs volunteer their time tn SUFFER are themselves sensitized tc formaldehyde. Formalde- hyde controls their being. Please keep this in mind and bear with us as we cuntinue our wurk to educate the public. Sf you have cuntacted us for Infoceaticn but have yet to receive it, please let us knew. We are not a large corporation pulling is profits to pay salaries nf employees, We are a large, non-profit corporatics desperately is need of funding, with chew- icafly sensitized volunteers eorking from their hnses across the cuustry. Easy of these volunteers are donating nst only their time, but also hundreds of dollars which they, too, cannut afford. Please keep this in mind when yuu consider a $20.00 membership fee and a separate dcnatinn tc SUFFER. TOE ROEVIRONMRSJTAL GUARDIAN is meant to be a quarterly smoslettor. Due tx the magnitude of wsrk that piled in we have been forced to combine our September and December Issues. A regular issue would be approxi- mately eight pogem. As yns can see, this issue is more than that, I apologize for this long delay as I realize mazy of yea have bees patiently awaiting its arrival. Again, thank you for your resposse. Please keep in contact with on. St is your newsletter and you help maize it ehat it is. Sincerely, Connie Dmrecek, Editor CuT CANCER STUDY The first evidence that formaldehyde mIght represent a carcinogehic rink for man was obtained in October 1979 from as osgoing animal experiment conducted by Ratteile Columbus Laboratories for the Chemical Industry Insti- tute of Toxicology (COOT). The preliminary renults acre revieowd by Federal Government nciestistn who con- curred sith the CIII conclusions. An the experiment progressed and sure data became available, the need for a full review of the potestial health rimkn to huxasn from chronic exposure to formaldehyde became evident. To accomplish this review, a panel of scientists from within the Federal Government wan formed In April 1980 under the auspices of the National Toxicology Program and coordinated by the Connucer Product Safety Commis- sion, The panel eesbern reviewed and evaluated the available published and anpublinhed information on the adverse health effects free repeated exponure to forwaldehyde. Acute toxic effectn and hypernensiti- vity sore not considered by the Panel since they had recently bees assessed by the Comclttee on Toxicology of the National Acadexy of Sciences (March 1980). The Panel concluded that definitive experiments exist which desonntrate the mutagenicity and earoinogenicity of formaldehyde under laboratory conditions, Formal- dehyde induced both gene sutationn and chroeonomal aberrationn is a variety of test nyntems. Ry Inhala- ties formaldehyde cauned cancer of the ouse in rato, Tb e cuncentrationn of formaldehyde in Inhaled air that caused nasal cancer in Fisher 344 rats are within the same order of eagnitude as thone to ohich humass may be exposed, The data prenently available do not permit a direct assenscest of the carcinogenicity of formal- dehyde ts san Epidemiologic studies on exposed human populations are in progress and may further clarify the situation, Other experimental and human ntudies nn toxic effects such an teratogenicity and reproduc- tive dinorders areas yet inadequate for a health risk assesunest. The COST twenty-four month study on animal carcinogen- Iclty has not yet been cospleteiy evaluated. Additional data are expected on the effects of prolonged exponure to lower donen of formaldehyde asd nn the possible corcisogehicity of formaldehyde in the boone. The Panel recommends that, for a comprehensive health rink ansesssest, further expericests be cosducted on the effects of other moden of exponure (ingestion and nkkn penetration), the effects in humans, and on the pharma- echinetics of formaldehyde in man and animals and the possible role for formaldehyde In reproduotive and chronic respiratory disorders. It is the conclunion of the Panel that it is prudent to regard formaldehyde as posing s carcinogenic rink to 47 CPSC MEMO Prom the CPSC Memo, October l98S~ In fineal year 1982, the ageney expects to screen 150 sew chemicals, to finallee a ban or labeling rule on Note, If you have a problem with formaldehyde be nure asbestos-containing products, and to develop/explore to call CPSC on their hotline at, l-8OD-63R-8326~ contrel options for ewn-foas, non-particle board/ply- is Maryland 1-800-492-8363. wood uses of formaldehyde. Rules covering tectile and Also ask them ts send pew their formaldehyde ~ tNPe dyes are also pro- packet. PAGENO="0052" 48 Editor's Note: Bolos is a letter I sent to CPSC prier tn their note no the proposed ban of UFFI (Urea Forsaldehyde Foam Insulation) on February 5, 1901. Save Us From Formaldehyde Environmental Repercussions January 2, 1981 BOARD OF DIRECTORS Chairman Susan B. King Vine Chairman Sam Zagoria Coeoissionwr U. Danid Pittle no,smue,n:s Coscsi sninner Edith Barksdale Sloan Cnmsissinner Stuart M. Statler of thn BO°'~o:'snn U.S. Consumer Product Safety Conoission s:su Washington, D.C. 20207 M:ens.:eeoM:: Dear Commissioners: ARIZONASUFFER As the sathonal nonodinator of tin 5,5,5~F,C,5, (Sure Sm From Formaldehyde Knnironsental Repercussions) organination, I snite on behalf of husdredn of families oho hare fullen :5, :,oce,Re::A:s, niotim to the outgamsing of formaldehyde in their hones as soil an the thousands of famil- ~B~:.:seoss~o5 ins sin are suffering daily but are yet unedunatod that forealdehyde may be the culprit. CONNECTICUT SUFFER Most of thnnen-i ctios hare bees foroed from their hones, hoses which they na-ned for all COORDINATOR: their life, o home they hoped to raise their children is, homes they ousted their grand- hildr t it th y f 11 h ha be hyp iti t f maid hyd S th i mantle. ~o~~s~e* Many of these families attended the Federal Cnnnuser Product Dafrty Comoinsios Reanisgs on Formaldehyde held in Oregon, Minnesota, Ceorgis and Connecticut one year ago. St san my snderstandisg froo CPSC at the time that connuowrn and the industry were to share the time equally, that you ousted to silos each wide equal oppmrtsaity. Rowener, betsees May 1978 MINNESOTA & NATIONAL and December 1980 The Formaldehyde Institute and the Urea-Foroaldwhyde Foam Ssduntry has had SUFFEOCOORDINUTOR: 26 porsowal meetings with the Coemaisslon. We, families who kane bees forced from our won- ha I t d h mama t floss i ily ff d th t 1 opo t t p lly itt th or Cosmissios sor ma s we afford thousands nf dollsrn to fisascerepresentatiews to speak on con behaif. While each wf us would like to sect sith the Commission, many handicapped ~W0FFEw ebotiom hare rwported they could not tolerate thc totanwo smoke, fragrasce, auto exhaust and other items gieisg-wff formaldehyde to tmaeel in the meeting, as forealdehyde lingers ,e~ss,m'o enwryehere. Aft en nonh sxpoeure, hUm would thwy nit through a meetisg and attempt to make someone sadwrstand what their life is now like. You swe, many of so are hypersensitlee to OREOON SUFFER items ccntaisisg formaldwhyde. Wheseopomwd to foroaidehyde pressare begiss to build is sos m,o~~ae hmad, it becomes harder and harder to remember chat oe ousted tw say, coscwstratiss is lost, breathing is difficult, oar nose feels like a hot stick mas shooed into it: we seed to get mo~:eo:.mR,anor,m into clean air to attempt relief. ~ONR~UFFER While sasuspectisg consumers costinuw to build and resodel hoses using produnts containing formaldehyde, knows in which they too may bow one sonsitioed is, tho isduntry nnntissen ti g ith CPSC t d 1 y y on d i i th p ibl ha f UFFS S F bros y 1980 CFSC promised consumers a decbsios would be reached prior to the next heating season. We WISCONSIN SUFFER are sow well into that scot heating season and more people are falling oletim. The isdontry argues that formaldehyde has been arwsad for 75 to 80 ywars, that war bodies ores process it. Were our bodIes made to handle the magnitude of formaldehyde that is being processed daily by the industry? Were our bodies made to handle the high leeds of formaldehyde outgannisg free UFFI, porticle board asd other materials in our hoses? In there a difference betneeo the formaldehyde our body naturally produces sad one's body breathing formaldehyde fumes or abeoeblwg it through the skin? Can infants, elderly and people with upper respiratory problems, the high risk group, noreire breathing formaldehyde costanimated air? Is this a wostributlsg masse of Sudden Infant Death Syndrome? Thm Formaldehyde Institute recently spent a hours is a personal meeting eith CPSC dimmasming the emanooiws of a han on UFFI and the potential ma swwr effwctn. First, how man anyosm put a dollar ualue on a huoas's health or life? Second, the 45% mascer rate (per CIIT, Chmmical Industry Institute of Toxicology, Canner Study) of rats expoSed to formaldehyde is of great concern to each nf us who has bees exposed to formaldehyde is our hoses, it sill almsys be is mind, especially those who lined is their contaminated homes for i to 7 years or sore. We mill alsayn fear for our future and that of our children. Third, the ClOT Cancer Study isdimates 120 cot of 200 mice exposed to formaldehyde started attaehisg ose another, I'm sure you are umare that the eajority of formaldehyde cosplaints indimated orobbinesu and PAGENO="0053" 49 irritability. I've had families express to me how formaldehyde has crawled into their being, overloaded their being and took charge of their being. They expressed the guilt they felt when they santed to attack their ohild, spouse or whomever was present. The attack may have been in the form of a vocal scream, that of a raving maniac, or physical abuse. Some of the attacks the victims can't relate to you as they know anyone who has cot lived It could not understand it. Fourth, the industry who disputes the CuT Cancer Study is is effect disputing their own work, as the CuT is formed of representatives of the industry, Fifth, CuT claims they cannot publish the cancer study for 6 months to one year, or more. Moe many wore people sill fall victim to this strong sensiti- wing chemical during this time? I have personally mpokwo with or received letters from numerous victims throughout our great United States, On behalf of these victims I plead with you to immediately ban UFPI as well as all formaldehyde used is living spaces. We ask this not for ourselves am formaldehyde has already overpowered our being, instead we ask it for the people who have not yet bees sensitioed. Canada recently placed a temporary ban on UFFI while they study the health effects from formaldehyde, Can't the United States shoe the sane concern for their oitiocns? You cannot know the torture we victims are living. But YOU can stop it from happening to more and sore families, Suns it may happen to you and your loved omen, We feel we can somehow learn to handle our problems created by fommaldehydw as the damage ham already been dose, but we can't handle the fact that our government is still ox- posing HUMAN GUINEA PIGS to formaldehyde. Hoe much longer will those families be held hostage in their son Si 1 MUTE, Cosniosioner King recently resigned from CPSC. Be sure to unite your Congresspernon about the appointment of the nec chairperson for CPIC. Stresa that we would want somoosenensitive to the formaldehyde issue, not someone C i S B oho could east to study the issue for another too years! N ti i SUPPER C ~ If overyone would mend a Political OpinIon Telegram (available through Western Union at an approximate cost of $2.UU) to President Ueagan, we could urge him to appoint some one sensitive to this issue. Send it 3-15-81! CPSC PROPOSES BAN ON UFFI According to the February 5, 1981 FEDERAi R8IIISTER, Part IV, the U.S. Consumer Product Safety Commission pro- posed a ban on UFFI (urea-formaldehyde foam insulation). Hucever, are you acare that this proposed ban may never take effoct? The thrwe to two vote in favor of a han wan an folloon, Chairman Susan B. King - yen, ban it Vivo Chairman Sam Zagoria - no, iet's label it Cmenissioowr H. David Pittie - yes, han it Cosomi sniomer Edith Barhndale Sloan - yes, has it Commissioner Stuart M. Statler - no, let's label it Indoor air pollution in a national problem and the federal government is considering what to do about it. Do you fool formaldehyde exposure creates a health risk? Do you feel your congressmen need to be informed? If na let then hnoo. They do not have the legal authority to spend our mosey freely, They need to know the feelings of those they represent. Go the following poge is a form titled `1 Want to Educate You to the Hazards of FORMALDEHYDE." If everyone will complete this form, I feel sure we can educate our reprenentativen tu the hazards of this chemical. WE dii NUKS TO COMPLETE THIS FORM NOW, NOT TOMORROW, EDT NOW. S canmot do thin for you, you have to tahe the initiative soc. I realize easy of you arc in a ntatc of tucnuil; my family in tue. but so seed to edu- cate those who haven't yet begun to understand, nou IS TOO TIME TO EDICATU TEEM. Please cosplete the form, eabe copies and send an folloon: i. Office of Secretary, U.S. Cunmuoer Product Safety Conoinnioc, Wanhingtcc, D.C. 20207 2. United Staten Senators, Washington, D.C. 20207 3, State Uepreseetativon in the U.S. Congrens, Wanhivgton, D.C. 20207 i. State Scnatorn and Seatc Reprenentatiomu 5. Cuogrwsssan Tolby Moffett 6. SUFFER Contact your capital or lmcal library to locate manen and addrennen of ycur Coogrvnnmem. Ucoenhec, they ounnut accomplish this tanh without the support of the 0,5. citioenn, You may alno give am oral prrnentatinn mm March 20, 1981. If you ainh to do ma, you mont notify the Office of Secretary at 202-631-7700 by March 10, 1981. For further inforoaticn, contact Harry Cohen, Program Manager, or Uuth Siegel, Project Manager, Office nf Program Munagemcnt, CPSC, Wanhington, D.C. 20207, 301-492-6453. MAIL TIE FORM NOW OR P0105 TO APRIL 1, 1981. (The Covoinnioocr oill only coanhder oanoontn received after this date to tho cotent practicable.) PAGENO="0054" 50 I WANT TO EDUCATE YOU TO THE HAZARDS OF FORMALDEHYDE Name ________________________________ Address______________________ My home contained lends of formaldehyde is the raogm of: less thao .01 PPM (parts per milhioo) - .50 to 1.0 PPM - .01 to .10 PPM ahooe 1.0 PPM .10 to .5OPPM I sos exposed to lecels of formaldehyde in my home for ______________ (period of time) before realizing chat sos making me siok. less than 1 sooth - 1 year to 5 years 1 sooth to 1 year - oxen 5 years The dealer/manufaetorer of my product san ________________ in helping me correct the problem, rery helpful dosonight ugly of little help threateoed me I estimate a loss of ___________ doe to formaldehyde is my home (include home repair, medical most, relocation, attorney fees, etc.). less than $5,000.00 $20,000.00 to $100,000.00 - $5,000,OD to $20,000.00 oxen $100,000.00 Healthwise, I feel formaldehyde caused or contributed to, - neurological problems respiratory problems hypersmnsitixity problems (small dosem of formaldehyde set off a reaction in me) - control of my health - death of family member - death cf family pet Please represent me, a U.S. citi mesas follows: - Formaldehyde prements no immediate problem - I cast a earning label on DFFI - I cant a earning label on all building materials containing formaldehyde - Restrictions should be placed on formaldehyde used in building materials I cant UFFI innned - I feel formaldehyde pa sea an immediate health risk and should be tanned from aU building materials Sore iomple need tc be put Is touch sith SUFFER. PAGENO="0055" The Oiens lived in their home six and 0 -half yearn hefore the formaldehyde sum discovered, "Six and one- half years!" Jonie Stenstad, Joan Oieo's mother ex- claimed. "I've aritten every member of the Minnesota legislature and I sas so cad that snmetimcn I didn't even read over my letters before I `ailed them. I matched my daughter fall apart after they eneed into their house." Joan Sims says that's not all her husband Roger and her parents have done. "Roger cane home from cork when I'd call him and when he didn't inns shut to do sithme snynore, Mon took over even if it wan midnight. I man impomsible to deal sith and they stayed by ne shsn all I did sun cry and sleep." Roger and their daughter, Janelle, did not feel well either. Joan's synptnsssere snob nore eosggersted. The doctors felt Joan cam caking her family 5mb also. Josie took her daughter to doctors and connoled and defended her when the diagnosim nsa labeled pnyohnio- gical. When Joan eon pregnant and the sympteassere some they sent to the Mayo Clinic and naoe home oith so definite diagonnin. Her fanily refused to have her ensxitted shen Joan herself begged then to do no. Her parents noted the pattern of illness at the house and improvement away frnn home The Oiens non live sith the Stenstads mince the for- maldehyde ass di mcovered first in their house and then in their mnbile home, both located mx the saom lot fec cRies from Jnan'm parents. Jonie nays the suooer's Formaldehyde appears in pesticides, pharmaceuticals, building suppiism, cnnmetinn, carpeting, clothing, plastics and literally thousands of pmodunts. It is also in car exhaust and tobacco smoke and the cause of eye and respiratory irritatmnn in sang. It in the most produced chemical in this onnctry and thc largest pol- luter of indoor air. So one can see boo cusp it snuld be tn get an overdone of formaldehyde. Rreathing difficultien are among the nont plamnts of those exposed to formaldehyde. Hnoever, shut could caane breathing difficulties in an adult, onuld caune death in an infant. Thin onuld explain the breathing irregularities found in none parentn of SIPS (Sudden Infant Death Syndrome) babies, since they onuld all be exposed to the name enva*rcomest, Other researchers also believe there in evidence 1mb- ing SIRS nad formaldehyde. Professor Peter Sreyense nf the Eneirnnsental Health Departeent nf the University of Wanhingtnn in Scuttle ham dane extenminc research into health probleon caused by formaldehyde eopnnare in mobil hnnen and thinhn formaldehyde in a ponnible caune of SODS. nary Ann Woedbury of the Sociul Ocr- omen Section nf the Wi neennie State Oxaith Departcent in intercuted in the effcotn nf formaldehyde enponure on iefnntm and children. A cooher of infantu in Wi noonni n bad to be honpitalined after eopnnure to formaidohyde in their hocea. Many of theueinfan ta nuffored free ~ an otnornul ineathing oondition cannonS y neon in SUDS nionics prior to death. huoid days really affected Joan and her family is a had say. They understand shy the Oi ensure making payae,its on and heating ten inunes and yet bane so bane to live in. The fact that Joan and her family ax eons sensitized to formaldehyde and other chemicals is understood. The sensitization rules sheen they shop and shut they bay. Roger, a car painter, in nco allergic to his job and the problean are apparent. Joan nays most people don't believe then because they don't see the Siens when they are sick. "How many nights I slept by the baby's crib afraid she sasn't going to get her next breath, but nbc sould be alcost normal by the tine we reached the hospital. She has an enlarged heart non but she didn't when she ass barn. When we were in the house ne scald tell relatives up north that Janelle, oar xldnmt daughter, can in the hxnpital oith neixuxes and a temperature nf 104 degrees. Then, shensesamid go up north to visit, Janelle would look and feel just fine. The relatives sandered shut so were talking abaut." It's too had you have to see or live formaldehyde pnisnning to believe it! With the help of hor family these past seems and one- half yours, Jnan feels she has not only survived with her marriage intact, but has grown stronger emotionally an well. "When doctams told me that my nerves were making me and my hmuband and child ill, I decided, well, I'd just control syserees then." That must have bees good discipline and her husband and parents oust ha ye sensed her struggle and stood by her. Dr. Alfred Preehette, Cosnismioner of the Massachusetts State Health Department banned foam insulation is that atate an a toxic and hazardoun substance after many health problems, including thone of infants. Eileen Schell and Ourbara Neoxan nf the Massachusetts State Consumer Affairs Departwent are bnth concerned about the serixus health problean experienced by infants and adultn in their atate, Sr. Hugh Wwstgaten in Minneapolis is concerned about health effextw ne childrnn and infants fmnn fxrealdehydw exposure after treating a nanber of theseoi otien. The Federal Cacsucer Product Safety Commission (CPSC) has receiecd aixnnt 3,000 cucplaints relating to health prob- lean caused by formaldehyde. Same of these nonplaints ineoleed infant deaths and also hnspitaliwaticns, and we believe the CPSC is lnniing into the pansibility of for- maldehyde causing SIDS. Ounnian studies bane shoca formaldehyde cauneareprxdux- tive problesn and birth defects, This tonic chexi cal has lno scieccmiar weight, easily panning tie placental and brain barriers, and can cause damage to the central ncr- noun syntes. Thin factor ocuid play an inportant rub im the nnnet of SODS. Sinon formaldehyde in uuoh a strueg nenniticerchevical, it sight be a good ideu tn nieoi for antihodien is SUDS nictica. "Dircotor of tie Department of Anounheui nlngy And lirnotur of Uenearch for the Sudden Scfunt Death Dyndrnnc Progrun on ueDl su Director of the Sntennbne Cure Cmlt at Ciii- Pnulth Center in Minveupolin, Minnenuta. 51 LIVING IT MAKES FORMALDEHYDE BEUEVABLE FAMILY HELD HOSTAGE IN OWN HOME FOR 2,287 DAYS! by Judith Olseth, Assistaot Editwr FORMALDEHYDE AND SIDS by CnnoDe Talsemn, Tedical I eseareher PAGENO="0056" 52 WIDESPREAD CHEMICAL SENSiTIVITY byBroce M. Small, P. Eng. FORMALDEHYDE'S AFTERMATH Bruce N. Small is no environmental engineer and lifestyle analyst from Toronto STJNNYHILL Canada. He and his wife BarBara have designed and built "Soonyhill Farm," a special home and halfusy house northeast of Toronto, that Is to he oned to test the effects of chronic chemical exposures on people's health. Suonyhill is designed to he as free of indoor chemical pollotlon as possible, and is 1k already responsible f or dramatic loprovements In the Small family's health, even be- fore fall completion of the interior of the building. Once the third floor `ecology wing' in finished, Sonnyhill will begin to play a role in the treatment and rehabil- itation of people who have bwccoe highly sensitive to everyday chemical eopcsores. __________ The Snail's bock, "Sunsyhill, The Health Story of the 80's," is available from Small * and Anmociatnn, Poblinhern, 8,0. #1, Gocdsood, Ontario, Canada SOC bA, for $12.95 US plus $1 pontage. B rocc and Bartara Snail also publish a quarterly sagawine for the - Toronto Branch of the Human Ecology Fcuodatics of Canada, a charitable orgaoiwation dealing with "ecological Illness." A free brochure on the fooodaties in also avail- cur' able from the aheve address. Being human, we all yearn for life to be nisple. Forsaldchyde outgaoning from foam insulation and a hundred other modern products is a cusplicatics we cuo all do without. But we even want our complications to be simple, and nature in proving clew again that this is a little tee such to ask. For many people SUFFB2O1Og from foroaldehyde exposure, avoidieg formaldehyde in not enough to return them to health. Is thin brief article I will attempt to explain why, and offer nose helpful suggestions. (life may ho cemplicated, but it is not inponsiblo.) We are hearing time and time again that coving out of a foroaldehydo-centamtnated house down not always turn the clock back. You and your family may find that yea also feel ill in year semi home or apartment, or in stores and offices. Sometimes the symptoss are lens intense, nesetises core than you eoperlonced under the heavy forealdehyde exposure. Our isoediats reaction is te seek and dentroy tho one villain again. If formaldehyde was responsible before, it is again responsible. We discover that there are hundreds of sources of formaldehyde and its ether chemical relatives. It comon out of modeen clothing and upholstery fabrics, some types of Insulation, ohipboard and plysood, and doness Even at that, cc feel again that surely once we hoes the list, and avoid these thiegn carefully, that the problem is solved. For masy it will be, and scare thaokful that there are people whose brush with such toxic exposures does not cause lasting problems. But for many others, another change takes place within thoir bodIes, and a see problem arises. It is called widespread chemical and feed seesitivity. It can develop after heavy or prolonged ex- posure is any one of many differost `nesnitioisg' chesicals. And for some, a heavy exposure is so soro than all of uw sight get ooasormal day in our polluted toostioth century life. `Spreading' of the sessitivity means that for some of us, the initial stags of reaction to one single Irritant gives way to new problems. Today you react to formaldehyde alone, asd continue to tolerate all the foods you cat and all of the ether 000000 everyday chemical contacts. But sees the ad verne symptoms begin to happen upon exposure to other chemicals. A porn on messitiwed on foossaldehydo or natural gas might next begin to fewl ill on exposure to tobacco smoke and per- fuse, then to the mild odours of synthetic rugs, upholstery and other fabric. They may then find it difficult to scar synthetic clothes sithout discoofort, or read a newspaper with its strong fresh odour of newsprint paper and ink. Plastics and automobile exhaust may join is. Foods previously tolerated may for the first time isa persos `s life brooms `allergic' fends. Suoser polles and your-round dust and mould sensitivities may also be aggravated. It is as if the whole body gets brooked off halasce. Many doctors may be pucoled shes a formaldehyde victim begins to exhibit thin patters. While they can believe that formaldehyde eight cause probless in concentration, thoy can scarcely believe that It in in 4pa~,e5,el everything, asd that it con cause much distinct problwms in such lee cancestrations. Tbeasnoer in a simple one; it Is no longer the only villain. In a very Inforeative pa pores titled "Feed Chomical Susceptibility after Environmental Chemical Overeoposurw& Cane Bintorlom," Dr. William Boa of the Brookhavwo Esvircomestal Unit in Dallas, Texan gives the following description of oldesproad chemical sesnitivity~ "Massive chemical overexposure has been ieplioated in a variety of sorious occupational diseases an cell as certain malignancies. The prement data suggest that soso chomicain can also trigger and propagate certain non-malignant inflascatery di neascs of otherwise onioc000 cause. "In his studien of patients oith food ounceptibility, Baodolph (Dr. Theron Bandoiph, founder of the Compre- hensive Envircomestal Control Unit at Aoerican International Hospital in Zion, Illinois) noted many persons to he intolerant to inhaled and ingested oheolcals at dose levels to which the general populatien is exposed daily. Through studies over the last JO yearn he developed tho concept ef chcsical sensitivity in an individual an the causative and/or propagating factoc of navy chronic diseamen of unice000 caone. PAGENO="0057" .53 Many of his patients developed susceptibilities to numerous synthetic chemicals after chronic ambient con- centration exposures. However, some previously healthy patients suffered acute, massive chemical exposures which precipitated widespread and persistent susceptibilities to numerous ambient inhaled and ingested chemicals. This usually resulted in inflammatory diseases such as recurrent colitis, arthritis, bronchitis, sinusitis, asthma or vascular-type headaches. `Patients in Randolph's series showed ehat appeared to be sensitization of various smooth muscle systema which resulted in the above clinical problems. Follow-up in theme patients showed an extremely slow re- covery tine from their multiple nensitizatione. In fact, those patients who did sot maintain strict avoid- ance of their incitants in all facets of life would rapidly lose their asymptoratic state and deteriorate into severe disabling symptoms again. "The findings in this (Ness) series of patients confirm Randolph's observations and re-emphasize the seriousness of exposures to levels of some chemicals In our environment which were previously considered safe, Since safety has only been detoreined in ntudleo of acute exposure to uniform genetic animals, a high level of error exists an to whet amount of chemicals are safe in the environment. Susceptible humans acting an monitors might help on to better determine safe levels of chemicals in our environment. "Once an individual is sensitized to a solitary chemical it is apparent that continued exposures result in a spreading phenomenon. Once this spreading occurs, reactions then proceed upon minute exposures. Spread- ing san demonstrated clearly in the patients in this series (described in detail in Hess paper.) After ~ massive gu~ppry to one (~y~ of individual jjxp~ became intolerant to pp~jxpt concentrations of ga~y others. The mechanism of this spreading phenomenon is unclear at the present time. `1 Dr. Rea's rather ominous results lend me to propose a `lifestyle' approach for the zany victims of foomaldehyde overexposure. Whether or not you have reached the stage of the `spreading' of sensitivities, it makes sense to con- sider a little preventive medicine. Life has proven that you can be hit by one chemical. Why not invent in a little insurance? tower your total exposures to the wider array of chemicals we come into contact with every day in our modern society. In many says, our isforsal experiments have shuns that `widespread avoidance' can be accomplished just as easily as `specific avoidance,' as in the came of formaldehyde. While building materials certainly play a part, and for the formaldehyde victim, it is critical to avoid more exposures of this particular chemical, they are by no means the end of the story, We are all capable of polluting ourselves over and over, even in the `cleanest' structure you could build. The many portable products, sprays, cleaners, perfumes and sundry poisons that me keep in our houses inevitably add a `sidosproad load' of chemicals to our bodies every day. Even simple avoidance of some or all of these can signi- ficantly lower our body's chemical load. The lighter the load, the more likely it is that problems triggered by formaldehyde will recede. Just as a fornaldehyde victim learns to be on alert for situations containing formaldehyde products, a person wanting to lower their total chemical load begins guadually to recognine where and when the chemical contact has been taking place is his or her life. Many small declsionm and choices during a day can give each of us cleaner air, cleaner food, and cleaner eater, all `plun' factors is minimizing the effects of chemical over-exposures. We can sever avoid all chemical exposures, and very few of us mill probably be able to avoid all formaldehyde cx- posures. But the strength of our bodies to handle theme poculiar modern onslaughts seems to depend upon the total stress we place upon them. In the long run, our best insurance may be a bit of prevontion - looering our chemical stress whenever we can, so that our bodies can fight off whatever we can't avoid.2 1Dr. William Boa's paper ens published in ANNALS OF ALLERGY, Volume 41, Number 2, August 1978. 2Further details on how to achieve a `low-chemical' lifestyle while still enjoying yourself can be found in `Suonyhill, The Health Story of the 80's," described is the introduction. 111&S ~CIJI~ MCHLL 1-i©MF L~FF~ I~E~SC1i)~ SUFFER has found all too numerous cases i ski h At isdimoriminate people have re-sold contaminated mobile asveca~°r'' you may oust to contact us at SUFFER homes to unsuspecting victims. If you were victim- handle the problem from ~ authorities to iced by forsaldehyde and you gave up ounership of your mobile hose, you should consider that it is very Recently sarnth 1 could be i tisi d if 11 bil h th ma h d al t i dt repossession or foreclosure of any type had been issued. In Minnesota, if you want to find out stern your home ~ to get rid of the ~rc ~ si ply gt th Highoay Buildi gcr d kn ho 5 11 it t diff t un peting marh the Title Search Counter. Bring along your serial ingn ~ ~ thrn:rn~ on thei~ dnai- yumbeuii1m~ht ~ ur b~1 d~' th$2 Co t iii g t t mart th th never. Sn a different state you say have to take differcot steps to find out this icforcutioc. by Stepheo A. Patternoc, Co-Director SUFFER PAGENO="0058" ~54 HCHO AND YOUR BEING Fornaldehyde can cause one to appear to be is a "drools- stapor." Chronic foroaldehydo Intoxication oao salt is licor asd seurolsgioal damage. In this country, most formaldohyde is made foss sethyl alcohol (methanol) shioh is saab more dasgercus than othyl alcohol (ethanol), froo ohioh alnoholic beceragos ace made. Durisg Prohibitioo "soonshine" shishey sos soda foss sothanol, and sam responsible for sasy oases of blindoessacd death. Forsaldehydo is a depressant of tho central nerecos systes. It has a rory los soleoolar weight (30.03) sO easily passos tho blood/brain barrier. Formaldehyde intoxication oauses death of brain cells and neurolo- gical dasago. Victims of formaldehyde poisoning can experiesce liver damage such as hepatitis, cirrhosis and an enlarged liver. Damage can also include a los platelet coast. The platelets aro responsible for blood olotting; many formaldehyde victims have abnormal blood 000gu- latico respuoses and ocyorimsem severe none bleeds, a cosmos health problem seen in formaldehyde sensitiord individuals. Anyone ohs has been seers~osed to forcaldehyde either at their con Floes nr at hone (fran area formaldehyde foam insulation, living is a mobile hone, particle bmard or other building materials, eto.) shoald have a blnod test to check their platelnt react. It scold also be a good idea to base a liner fuoctinc test. Formaldohyde is a protoplassic poison and isterferes sith tho body's use of cxygen, in each the some say as earbcs sonocide. Because of this lack of oxygen, thore is a physical dopresslsg of the f000ticsisg of the brais and sasnous systen shich sos result is neurological damage, sestal depression, cosfusion, sesoryloss, comaandevesdeath. Formaldehyde cas affect an isdinidual's thinking, mak- ing one feel "dcpey." Because of this, avd the fact that mast people are not anars that many health proh- less can be massed by environcestal toxins, a live for years is a hnse leakisg formaldehyde istc the esvlronoest and not he asare of ever-iscreasing health problems. by Carol Falseco, Medical Researcher Based on her research into tosicology, goeerssestal and sodieal publications. A PARTIAL TRIUMPH iy Mesa Sprague, Nebraska/Montana SUFFER Cnsrdlnator I hare bees disabled due to cheelcal sensitivities, especially formaldehyde, sisce May 1, 1978. Ohms I had to finally accept that foesaldehyde had sot cnly robbed so cf sy health but it had also forced se to end a toelve year career in a job I loved, se started tho tedious prseems of filing fcr my disability in- surance. This was is October 1970. The insurance company has lied to so concerning sy dcctcr's reports, oy es-bass' ropurts and other things. They havo iosulted sod kichod me shen I massesbally and physically at sy lasest. Good doom soercoco evil, hosever, On December 31, 1980, I recoived a call from the cccpaoy. They are goiog to honor sy dais. Rut, cy retiroment fros cy job has just been dnnimd, so I an starting the case hattie all scm again. God gi ye on all strength. WORKER'S EXPOSURE The Baticnal Institute for Occupational Safety and Health (IISOUH) estimates that about 1.6 sillica sorkers a year are exposed to formaldehyde, about a third cf them in health care. This accounts for the fast that SUFFER is hmarimg foss oictismahosere exposed to formaldehyde through their cork, lose havo been art teach mrs she acre scamitised by their paints and gas-fired kilns; hospital pernonsol who serononnitimed to disinfectants. Cossotnlogints. Did you know they use formaldehyde as a dhsinfectaot share rollers, combs, etc. are stored? Morticians, of coarse, use formaldehyde for eshaloisg. Textile corhern - coo victim felt she so s secsitized after tho backing of thm material she cam corking with powdered cff. The list in endless - printers, painters, carpenters, secretaries, retail clerks, biology teachers (and, of coarse, students) firesro. As in our hose life, am are fisding oar corlo mmvirnnnent loaded cith chesicals. Productivity sill increase, abmcoteeissolll decline shen the steps arm takes tn loner the pollution in the office and the factory. Employers, usioo leaders and fellos work mrs seed to be informed about the hacards of such ohemical over- boding. Through education we mill all he breathing cleasor air someday. VICTIMS OF FORMALDEHYDE? Oas your pet sick or did you loseapet ohile in your forsaldehyde contaminated homo? Do you koco of someone using products ouch as particle board fsr animal sheltwrs? We'd like to hear from you. An editorial saw published in thm January 1981 issue of the Joursal of the Aserisac Medical Association urging the has of area-forsaldehyde foam insulation! "C URGENT!! URGENT!! URGENT!!!! Heariogs may be held in Oushingtoo, D.C. on formal- dehyde in the next fwwseehs. Coogressman Colby Moffett nwedn to hear from you to knoa the extent cf the problons people ore basing aith formaldehyde. floRRe ante to him at 127 Cannoo Office Building, Washington, IC. 20515. He aunto tu hear frmm us! PAGENO="0059" 55 ATTENTION PROFESSIONALS AND FORMALDEHYDE VICTIMS We are still is the prooess of compiliog a list of professionals (legal, medical, soientist, chemist, etc.) who are concerned with the adverse oonsequen ceo of formaldehyde. Many victims have indicated they sought assistance from medical aod legal professionals who did not understand their problem. Most of the medical professionals were not taught the health ram- ifications of formaldehyde in their medical training. This has complicated some of the legal processes. Victims would like SUFFER to put them in touch with attorneys and physicians. Please ask your prcfesoion- als, if knowledgeable in the area of formaldehyde, to send us a letter of reference indicating their areas of expertise, number of clients/patients relating to formaldehyde, manufacturers they have dealt with and any other pertinent data. As soon as this list is compiled we will make it avail- stile to anyone desiring it. Please send a self-addressed stamped envelope. The Sixth Basic Seminar of Clinical Ecologic Techniques for physicians, nurses and tehonicians is scheduled for June 12-17, 1981. For more information contact Dr. Sasrenco D. Dickey, 109 West Olive Street, Fort Collins, Colorado 80524 (303-482-6001). disc ask for information on the Fourth Annual Informal Study Conference scheduled for August 27 through September 1, 1981. Victims, plea se cnns~e your physicians to attend. TESTING FORMALDEHYDE LEVELS by Nancy Clay My bombard Mike and I oere asked by the Federal Consu- mer Product Safety Commission to give testimony at their formaldehyde hearing held February 1980 in Minneapolis. It was at this time we were introduced to the SUFFER crganioation. Since that testimony I have subsitted an additional one an an updatc. There are some important facts I'd like to bring for- ward at thin ties. Many consumers have their homes tested for formaldehyde levels after suffering health problems which may be attributed to offgassing. If their home is tested, after months of health ailments, it may nose during cold winter months. It's important to remember that offgamsing runs in cycles. A minimal reading in the winter time can be quite high during stmmer months. We've had four readings taken in our sobile home, Our daughter was hospitalized Pebrsu.ry of 1979 when our level a were 0.23 ppe. Four months later they registered 1,2 ppm; is August, 3 ppm, In Jane nf 1980, it was at 1.8 ppe, a rise of 0,6 ppm from the year before. The cycle begins again. So, when your testing agency, usually your County Board of Health or State Health Department, comes to take your tests and the results show minimal levels, please note the nutnide temperature and humidity. Don't let thes talk you out of the idea that formal- dehyde is cot the root of your family's health prob- lems. Heat and humidity have a direct effect on the amount of offgassing. This was how our first analynis in February was ex- plained to us. The testing agency suggested our levels were too minimal to worry about. As the National Academy of Sciences determined, there is no tolerable level for the general population. Also, childres have died from what a testing consultant calls a minimal level. Please keep this in mind and have additional tests run, if possible, throughout the course of a year. BRUCE SMALL TO TALK FOR SUFFER MEETING--MACALESTER COLLEGE IN MINNESOTA Brune M. Small, a Cccadlan engineer and environmental designer, and president of the Toronto Branch of the Human Ecology Foundation of Canada, will speak ahout healthy homes and lifestyles on Sunday, March 22, 1980 at 2,00 p.m. in the Weyerhaeuser Chapel of Macalester College in St. Paul, Minnemota. Polluted indoor air in North American homes, schools and workplaces is quickly eroding many people's health. Creating a chemically clean and healthy home is a major chailonge. Mr. Small will discuss some of the un- suspected prohiemm and opportunities in building or chenging households, for better health, - safe building materials, and hoe to survive through makeshift and ingenuity when you hove to compromise. - hoe a family's lifestyle can pollute the most `ecological' house, and chat to do about it. - hoe all of us can reduce our personal pollution intake drastically through lifestyle training, no matter where we are and how our homes are built. Small will also explain how avoidance of as many types of chemical exposures as possible may be helpful even if only one chemical (e,g. formaldehyde) triggered your health problem. An advocate of "step-by-mtep" sedicine, Small will stress throughout his presentation the importance of continuing attention to esvironmest and health rather than `one-shot" solutions in our all-too- common searoh for magic answers. Bruce and Barbera Small are authors of the hook "Sunnyhill, The Health Story of the 80's," and together have built Sunnyhill Farm, an ecologically safe home and information center designed for people with severe sensitivities to our modern chemical environment. Sunnyhill is fnrty miles northeast of Toronto, Canada. Their story was featured in the January 13th issue of Family Circle Magazine. Small's talk is hoped to be a fundraiser for SUFFER. There will be a $2.00 donatinn at the door, Please nontact Connie Bmrenek (612-442-4665) or Joan Oien (612-436-7293) if you plan to attend. PAGENO="0060" 56 SUFFER ATTENDS SOCIETY FOR CLINICAL ECOLOGY SEMINAR hy Judith Ulneth, Assistant Editor For those of you she hare dereloped ecological disease as a result of forsuldehyde, clinical ecology doctors nay he for you. Coosie and Tos Snrecek and I atteoded the Fourteesth Advanced Seminar in Clinical Ecology at Callanay Gardens is Pine Mountain, Georgia cc November 3rd through the 5th, 1980. The Society For Clinical Ecology, ohich spoosors these seminars, is nade up of doctors rho cork oith their allergy patiests, makisg detailed clincial observations about thoir physical and enotional health, osoircorest, and past history. Ferns of troatneot vary fran sinpie avoidance of allergic substances, to desensitizing patients by moo- culations, sublingual titration (drops of diluted substances applied under the tongue), food rotation, to enniron- nestal care uvits, Environeentai care units arc for patients rho are so sensitive to the envlronnest that they rust oithdrae frnn the corid for a tine to detoxify their body and stabilize their health. People east learn to stinulate their ianune nysten (eoanple, Vitanin C) and acoid those things ehich harper the ianune synten (ox- ample; antibiotics). There are a number of environmental unro units about the nation such as Dr. Willian Sea's is Dallas, Touns and Dr. Argubrite in Watertonc, South Dakota. Dr. lurid Morris cf laCrosse, Wisconsin treats hypersensitivity to foroaldehyde an an allergy rot as a toxic problen. His treatnent is avoidance of forealdehyde and noblingual titration. Tbc ocoa*nur té,oh placr, of coarse, before it uns anrouncod that fcroaldchyde isa carol roger. Avoidance noons BIn a foolish solution since fc~idehydc encoepasses nodern life, but Bvuoo Soall of Gondocod, Ontario, Canada strrsned in his secinar speech boo every avci dance can add up tc a healthier you. (See article by Bruce Small elneuhere in thin neosletter.) SUFFER nonbors cur cell aunre of hoc their boors ran be the source of contanination and irene Scull and another ecologist, Francis Silver, FE,, Martirnville, Wont Virginia, hr cx over nero about iou yore hone can make you ill. Mr. Silver listed products that should not be xtorod in the hono. The lint included paintn, polishes, cleaning compounds, and insecticides, He alno explained hoc he oaken an `Ecologic Hounc Call" to see that pationts also have proper chimneys, vonts, and boating nynteon in their horns. If you desire to listen to SUFFER's unedited tape cassettes of the three day rent rae and syllabun on it, rend a $65.00 doponit to SUFFER, RR1A, Boo 14RC, Wuoxcia, MS 55387, Thin dnpxsit xiii put you on our list (firnt come, first sorced). You may retain tapes and syilubus for ton days. Upon retoro of tapo cassettes and syllabus in good ronditiccarefund of $35.00 xiii be roturond or. the righty-four page nyilubus for the Socirty for Clinical Ecxlogy's Fouxtreoth Advancod Seolnar in Clinical Ecology in available by sending $15.00 he Lanrenco S. Dirkoy, M.D., 109 Went Olive Strect, Fort Collins, Colorado 80524. Alno availahir are riotoen oditod cassetto tapes. Sond $125.00 tx Ensta-Tapo, Inc., 1139 South Fair Oaks Avenue, P.O. Box 2926S, Ponadexa, CA 91105. Ask fcr a catalog cf available tapes. Be sure to nentlor that you arca member of SUFFER nhen naking a req000t. Note, I'd like to thank Dr. Million C, Crxxk of Jaxksxx, Tennennoe and Dr. Lacreorc S. Dickey for their interest in the fornaldehyde preblen and for their bringing thin very inforoative nonisar to cur attention. SUFFER's forealdehyde fliers nere carried hone by nenirur participants throughout tho Oxitod States, Canada, England, Nez Zcalnnd and Australia. If you could like to attend future Clinical Ecologist Semixarn an en did, please unite tx Dr. Dickey. Watch for nore irfornation on clinical ecologist conferences in the future. F4)FS IJFFI I[VF~ WCI~I1~ Orca-foan insulation is to insulation an military 2) tho "U valun" of xrma-forealdehyde fxan mmclx- music is to nusie, A repxrt by Jason H. MoDxnagh, tion ohich can advertined in literature as beixg physical engineer of Rochester, Mirocscta, after 5.5 in, ix roality, lens than 4.4; studying numerous boson nblob have been "insulated" through the spraying of urea-fear insulation has 3) thor e arm instanoos of USFS shore tho cffgaenirg determined tin follczing~ and release of untor vapor in no groat that it has unused the pooling of plyeood in a patters to 1) the average shrinkage in all urea-foam mmix that of the shrinkage no that ehes viezing a insulation is approxmmatoly 14%. Thin call you can eon the plyoxod starting to peel hack moans that rot eithstandirg your belief off the call in the sane area chore the insula- that you are having the entire inter- tier material ham brehmn doun; sticen of your calls, roof, reling, etc. filled zith insulating material after the The significance of theme studies in that isdiciduain material has been left in the call, there eith OFFI that have not felt or suffered health ros- in shrinkage so that at least 14% of the sequences might, nevertheless, ha yea cause of action arma chick you thmught ems being insula- against the installer and/or manufacturer of the USFS ted turns out not te be insulated at all is that the insulation does not cork an insulating eateria]J PAGENO="0061" (Save Us From Formaldehyde Environmental Repercussions is a grass-roots type organization established by concerned per- sons who have suffered from the health, emotional amd finan- cial effects of living and working in areas contaminated by chemical substances the most prevalent being formaldehyde. We want to provide information and educational material to the public about possible hazards, remedies and safeguards imvolving chemicals used in construction and remodeling of home and work areas. WANT MORE INFORMATION??? CONTACT: S.U.F.F.E.R. Newsletter available for $20/year. IF ENCING SOME OF YOU ARE ~4ItlIItI1IIIIIItIItItIItIIIIIIItttIIrI~ THE FOLLOWING SYMPTOMS YOU MAY WANT TO HAVE YOUR HOME/WORK ENVIRONMENT TESTED FOR FORMALDEHYDE FOR MORE INFORMATION CONTACT: Connie Smrecek National SUFFER Coordinator RR-1A, Box 148C Waconia, MN 55387 612-442-4665 Possible symptoms include: Earaches Skin rash Diarrhea Exhaustion Headaches Nausea, Vomiting Congestion Depression Irritability Flu-like symptoms Rummy eyes Asthma-like symptoms Sore, strep throat Many, many others Runny, bloody nose As well as potentially causing /~RMA LD EHYD infant deaths (SIDS) and cancer .F.F.E.R. C,' DO YOU FEEL BETTER OUT OF YOUR HOME S OR WORK ENV I RONMENT THAN YOU DO IN IT? IF YOU LIVE/WORK IN A: New home/building Newly remodeled home/building Mobile home/unit IF YOUR HOME/WORK ENVIRONMENT CONTAINS: Urea-formaldehyde foam insulation (Ban proposed by U.S. Consumer Product Safety Commission) Particle board Panelling Carpeting Plywood IF YOUR OCCUPATION EXPOSES YOU TO PRODUCTS CONTAINING FORMALDEHYDE, YOU, TOO, MAY BE A VICTIM OF FORMALDEHYDE! PAGENO="0062" 58 ILLINOIS UPDATE, The city of Woodotook, Illinois shoon its concern for the health of ito oitiooss. Does your city?? The foilooiog ooses free their Noildiog Codo Aseodeest: ORDINANCE NO. 1576 AN ORDINANCE AMENDING TAN SECTION 4-315 OF THE BUILDING CODE OF THE - CITY OF WOODSYOCK BE IT ORDAINED by the City Cossoil of the CUT? OF WODDDTOCK, MoHenry Cosnty, lilinoin as foiloon Section One. That Deetion 4-315 of the Bolldiog Code of the CITY OF W001STOCK, entitled, "Thermal Innslatiosn' is hereby aeosded bp addIng thereto an additional subsection ouch shall read as folloos: "(A) The use of Urea-Fornaldehyde Feas Insulation is prohibited." WASHINGTON UPDATE: Eileen Cole, Washington State Coordinator, sponsored a public ceetiog on forcaldehYde last Fall. She has unties the following report to help others desiring to set op similar seetings in their area: (A special thanks to Naomi Kelly she ease fros Oregon to help uith this seeting!) "The panel prenen tati cc consisted of Professor Peter Breyense, sell-icons for his rescuech on formaldehyde; Dr. tkvid Rancher, clinical ecologist, resoseended by noted allergist Dr. Theros Randolph; and a representative of Consueer Products Safety Cosoisnios. I seat soon roleanes to all the looal o005papers and TV ntationn and public servo*ce asosuocesonts to the local radio stations. Too ceospaporn had a snail article and too radio otati005 did a taped istervimo. A TV station gave high" lights that sight, ohth core details so their corning neon progroo. Viotiss cans as a result of neon coosrnge sod a sses~per ad that ran for a fec seeks. I invited representatives fros several state and federal agenoa* en. The Federal Trade Coeoolnsion and the State Deportnest of Li sensing sent representatives as observors. Doe neoator aod foor representatives cans. The senator then arranged a public hear- ing before a Senate nubsoscittee dealing oith forsaldehyde is sobilo hoses. The overall expense of the meeting sun under $1UO.UU inslodisg rental, copying expense and postage. I as as inex- perIenced, average per550, but the arrangements for the public ceetiog eere accosplished easily." Note, The follooisg can published is CPSC'n Publis Calendar, Vol VII, No. 49: Jerry M. Ojorlo, Seattle District Office, attending a public seetisg on forma3444y4di4H.jOobildJY0RNN_86~Ho!iNusMd HEH9NHSR sponsored by Save Us Pros Porsuldehyde Unviroosental Repercussi~UPFEN;7 p.m., Kent, Washington. SUPPER requentod the seetiog. For inforoation~ Mr. Bjork, (yod) 442-5076. MINNESOTA UPDATE: A bill sill be introduced this session is the Bisnesota legislature and in expected to pass both Roases. St sill set a level of 0.1 pps and sill have a canning requiresent. It sill also change the ntatste of licitations on personal injury from one year after you hans made a demand for relocation (ohich it is at present) to sic yearn. The Departsost of Health sill be left sub the responsibility only of detersining the bent tenting procedure. The Industry (shack indicated ohllo the Minnesota bill can being oossidsrsd by the legislature that it had so objections to it) after the enactment of the bill, filed a laessit seeking to onjois the enforsesent of the bill and further, sith respect to pending litigation, sowed to dismiss the canes filed on the grossds that the statute panned by the legislature in 1980 nan caconstitstional! A hearisgoith regards to this matter sill be held before the Honorable Harry MacLaughlin is the United States District Court, District of Minnesota (Minneapolis Pederai Court Rosse) on Tuesday, March 17, 1981, at 9:UU as. Any victims sho nould like to shoe soral support by attending and/or could like to come out of interest are so loose to attend. Judge Maoiasghlin'n courtroom is located on the fifth floor of the Federal Courthouse An Micaeapolin. TEXAS UPDATE: A psblio semisnr on formaldehyde and the environsest san held last Sesenber 1980 at Baylor College School of Medicine in Boston, Tecas. CALIFORNIA, CONNECTICNJT, OHIO UPDATES: Hearings have hems held is these states on formaldehyde and its nffest on our environment. PAGENO="0063" 59 DEAR READERS: I ount to peroooally thank each of you oho took the thee to onto per0000l lettoroaod complete the quew- ti onmairo iocluded in Jume `s neooletter, THE ENVIRON- MENTAL GUARDIAN, Maoy oho wrote had their oonld coilopoiog around thee or have lived with thaw prmb- lee for oeveral yearo. If you could ooiy read all the lettero that poured is you oouldo't feel ow though thio aao happooing only to yea and your faeily. Dad to nay, it is happeoiog throughout the country. We all feel we have beeo harmed greatly by thi soenui- tiwieg chemical known an foroaldehyde. A chemical ohich crawls throughout your very being and taken control. I am oorry I maccot reply directly to each of you as I could likw to do. U do hope you'll continue to onite me, however. If I've failed to reply or wood requested information, please let em knoo. Please try to complete the questionnaire furoished sith the previ mum neoolettwr and sail as noon ow possible. Every piece of lnforoationreoei ved helpo the organi- watioo educate the public who in turn can demand that controls be put on formaldehyde. We are here to liotmo and help you in every asp we can. would like to nhorw with you a small portion of vonoecto from the letters of our victimized friends: Dear SUFFER., We have been damaged greatly from formaldehyde. My wife ham lost both feet becaune of nerve collapse, gangrees for eight months, then amputated. Both hands numb from wrist out as many of those things listed on your chart. I am suffering from numb bonds froe wrists out. Legs scab from booms doso, won't keep my tolaocw without a cane.... As you can owe, it would take approximately $45,000 to replace our total looses. I had plamaed so retir- ing July 12, 1900, as I will be 65 ywars old, but sow S eaoomt as myincome oouldmot be enopek forrentin an apartmwst... (This family lust their sobilw hosm. I am 30 years old and I'm a formaldehyde viotic dis- abled for two years. Even is thw absecew of an aller- gic history, individuals may bee oem smositiwed with repeated formaldehyde exposure aod there is mc reliable way to prediot thomw at ri sic... (This lady oassot go any place without becoming sick and has lined the life of a recluse fur over two years.) At presest I om living outside. I had to move to the (icnyon to get out of a neighborhood that keeps spray- ing lawn and trees and seeds.... Then I developed chest pains, numboess and pain in my left are. My chest felt like it sos full of liquid. Then I developed breathing problems. It got so tad I had to take a deep breath every wouple seconds. S hams I needed help but wasn't prepared for shah I gut. Doctors gave we Valium and told me it was all in my head. After many doctors and bills and getting no- ohere I about gave up. I just had nushere to turn to for reiiwf. Whenever U suald drop off to sleep U sould suddenly jurp avd awakes. I finally figured out this was be- cause my breathing had stopped. This was happening to my too childreo, tco.... Our baby was one month old ohms she stopped breathing.... Received your paper and, bell eve me, my husband and are very glad someone besides us are trying to do some- thing to help get rid of this terrIble problem. We still ha ems so it pending against the builder, ohm as I waderstand it, Is still using the urea-formaldehyde foam iwsulation, My granddaughter, 6 years old, suffered a cardiac arrest. Doe month lot en she suffered soother cardiac arrest. A blood sample was sent for testing. It came bock puni- tive, formaldehyde was Is her blood.... Ow sincerely hope SUFFER will reach others and also that formaldehyde is boomed from the market. Thank you agais, I now bore peace of mimd as to what happened to my body. It was like a nightmare.... Something strange happened that sister which S now believe was a direct result of formaldehyde pmisoning. The house was old and I boos there were bats hiber- ________ (Cootinued on semi page) SUFFER, A BOO-PROFIT ORGANDZATION If you macinterested is imlpiag ~ ~ let us hear from you. We can't do this job alone. $ Tam deductible donatins enclosed (plea am seed any ammant you can afford or sullest) $ One year ($20) membership dmnatisn enclosed; this isslsdes THE ENVIRONMENTAL GUARDIAN. If yea have already paid your yearly membership, please check kerw . If you east afford tke $20 at this time, please let us icons. Yes, S `d like to be a SUFFER Coordinator for my state. __________ Yes, I'd like to assist my state SUFFER Coordinator, ________ Yes, my oceupatims allows me to offer services, materials, etc., suck as: Single copies of TEN ENVIRONMENTAL GUARDIAN are available fsr a $5.00 donatios for a sisgle espy or $25.00 for 10 espies, PAGENO="0064" ~-~O~ILBAG cont'd) nating in the attic. Too of those hats found their say into our living quarters that sister. They nero easily caught as they dido't have the nip that hats do. I resenher cosdering ohy those hats ease out of hiher- nation? Oy soot hint of trouble sun like a punch is the stooaoh. After shooing vague syoptoos of usde- terohsahle origin for ten dayn, cy daughter (8 years) suffered too nelouren in leon than 12 hours.... I sun very pleaoed to receive a copy of THE ENVIRON- MENTAL GUABSL'S neusletter. I as only sorry that ouch puhlieatieos avd assistasoe coconut availahie too bog yours ago.... We used to be a happy, sorsal fuoily is a little house. Nun cc are a sickly, unhappy fanily oith a huge, heautiful house that cc sunset live is.... Again, cc appreciate your letters and phone calls. They help us help you. I understand the turmoil iv your lives and hoc this ehecbcal affectn ever~hisg you do, but please keep in mind that SUFFER sluoc ca550t educate other victiss, physicians, and the goverssest. But YOU sue if each of you oill folloc this organiced oovnoeot. Please sit doun son and unite your letters, ecopiete your forms, sake copies of your infcroatiuo, sake your phone calls, punt your fliers, pass the sort to every- one Lncludlsg reporters. I can do sy sharo, hut I cunsot do your share. If you feel fornaldehyde is hasardous to coo's health YOU need to sake yourself heard. Thank you ms very such for your contribution. To- getkereecill he heard and understood. 60 MIi~ILiA l[VI[~1FS Bolos is a list of articles published or TV programs revicoed ohioh deal sith foroaldehyde and other esvirconestal coocerss. You sight east to unite to the magasines and TV stations requentisg a copy of the article or transcript of the progracs. Be sure to nestles in your letter that you are a victim of fcrcaldehyde sod a somber of SUFFER. Preveotico, September 1980 Qfga9jurdeoloW, Deceober 1980 (Carol Cecugh) 98poR8ggr, published by Eovirosoestal Aetioo Fcunda- tics, 724 Dupont Circle Bldg., Washisgtoo, D.C. 20036 Eseiroomeotal_Action, Deconher 1980, Vol. 12, Nc. 6 Suite 731, Connecticut Ave. NW, Washington, S.C. 20036 CPSC Memo and CPSC Public Calesdar unite, U.S. Coosuser Product Safety Co,sojssios Washiogios, S.C. 20207 Carcinogen Information Program Washington Uciversi ty, Canpus Boo 1126 St. Louis, MO 63130 (Send a long, self-addressed stamped envelope) Phil Donahue tntoreioos Sr. Alfred Zamo Send $2.50 to Sosahue Traoseripts P.S. Boo 2111 Cisciscati, OH 45201 Tho ManNcil-Lehrer Report en formaldehyde Scod $2.00 to, MaoScil-Lehrer Report 0/0 Transcripts P.O. Boo 345 Nec York, NY 10010 David Norcoito Fight Back CBS TV Burbank, CA 91523 I THE ENVIOONMENTAL GUABSIAN IS PUBLISHED BY SUFFER AT WACONIA, MINNESOTA Editor, Cosmic Surecek Assistant Editors, Patsy Alfcrd and Judith Ulseth The ecntcstn do sot necessarily reflect the viess and pclicies nf SUFFER or its sdeisory heard, nor ~ esjrsencst CHANGE OF ADDRESS? PLEASE NOTIFY US. Ccosic Smrcnck FIRST CLASS BUFFER oNla, Boo 148C Wacosia, MN 55387 ADSUESS C000ECTION REQUESTED PAGENO="0065" 61 ~-4HE S AVE us F F E R JUNE, 1980 REPRINTED DECEMBER 1981 ISSUE NO. 1 97-153 O-82--5 PAGENO="0066" Board of Directors: Steve Patterson, 865 LaFond, St. Paul, Mi 55104 (612-489-3759) Connie Snrecek, 108 East Lake Street, Waconia, MN 55387 (612-442-4665) Michael Young, P.O. Box 127, Cirtle Pines, MN 55014 62 Consulting Attorney: Marc 0. Kurzman Typist: Ann Miller, our special thanks! History: SUFFER is a grassroots-type organization established by concerned persons who have suffered fron the health, emotional and financial effects of living and working in areas contaminated by chenical sub- stances, the nost prevalent being formal- dehyde. Activities: 1) To provide information and educa- tional material to tfle public about possible hazards, remedies and safeguards inuolaing chemicals used in comstructiov and reoodel- ing of hone and work areas. 2) To aid families and individuals who have in fact suffered from the effects of chemical poisoning especially from sources over which they have no control. Purpose: To promote the general welfare of the public and preserve the right of the individual to live and work in an environ- ment free f rem hazards produced by the use of chemicals which can be detrimental to his/her general health and well-beina. NEED LEGAL ADVICE? SUFFER is building. We're trying to expand and help each other out from the perspective of under- standing what our problems are. Some of these adverse consequences are becoming known only because we're able to take a look at a volume number of cases, we're seeing patterns, if you're not seeing them, you don't know about the pattern. So that's why it's important to people whether they want to change laws or bring a law suit, or if only to understand the harm we've endured. SUFFER is trying to coordinate with plaintiffs' attorneys. If your attorney would like to con- tact other attorneys who are better educated about formaldehyde, or you do not yet have an attorney, contact SUFFER. We will send you a list of attorneys who are knowledgeable in the area of formaldehyde, type of expertise and/or cases handled previously. Please send a self-addressed stamped envelope. *There have been three cases settled to-date across the United States involving formaldehyde. One of theo,where there was no significant 2 personal injury, resulted in the recovery of $58,000. iet ENUIRON8ENTAL GUARDIAN is published by SUFFER (Save Us Frvv Formaldehyde Environmental leper- cussioms). It is meant to be a quarterly neas- letter for formaldehyde victims and by forvalde- hyde victims. If you'd like to subnit an article for publication, please do so by August 15, 1q00. If possible, please type it double-spaced yr print it. We'd like to hear from you! Yembership is $10 per year; it includes THE ENAIRUNMENTAL GUARDIAN. © cxmovouvono em SUFFER SUES NATIONAL Listed below are the SUFFER Coordinators for other states. If you'd like to help them, or become one, please vrite Cnnnie Smreceh, 100 East Lake Street, Wacomia, Minnesota 55307. ARIZONA SUFFER COORDINATOS: Dan Devlin 4048 East Tierra Buena Scottsdale, AZ 05254 602-971-5900 CONNECTICUT SUFFER CU085INATOR: Carol and Al Palmero 4 Sherry Drive East Hampton, CT 06424 203-267-8606 IOWA SUFFER COORDINATRO: Nancy Clay Boo 135 Solon, IA 52333 319-644-2004 MINNESOTA AND NATIONAL SUFFER COORDINATOR: Connie Snrecek 108 East Lake Street Waconia, MN 55307 612-442-4665 NEBRASKA SUFFER COURSINOTOR: Menu Sprague Route 1, Box 113 St. Paul , NO 60073 300-754-4901 OREGON SUFFER COURSINATOR: Naomi Kelley Route 2, Box 50 Willamino, OR 97396 503-876-5294 WUSHINSTUN SUFFER C0URDISATUR: Eileen Cole 0424 South 26Uth, Space 57 tent, Hashinqton 9AU31 206-ill -26SS WISCONSIN SUFFER COURUINATOY: Mary Kappes Route 4, Box 293 River Falls, WI 54U22 715-425-1104 PAGENO="0067" SUFFER INCORPORATED The purpose of SUFFER is explained on page one of this publication. However, we wish to give our readers a little nore background on how SUFFER on gi noted. Three fanilies in ginnesota with fornaldehyde problems were able to contact each other after seeing their reports on WCCO Action News, Channel 4 in l'linneapolis, Larry Schnidt reporting (see following article). With Larrys help these three fanilies banded together to form a corporation known as SUFFER. Through endless hours of research, phone calls, letters, and a will to win, these three families have established an organization which seeks to inform the public of the hazards of living in a chemical environment. Their main goal has been supported by many other victims. PLEASE HELP SPARE ATHENS FRAN THE SUFFERING AND MISERA WE HAD TA AU THRUUUH1!! However, there is one large obstacle which stands in the way of reaching oar goal--MONtH. Like nost non-profit corporations, we exist only through the support of concerned persons like yourself. If woo feel there is a need for SUFFER, S)vto..oiy.ase support our efforts by sending whatever .oo.a...too~ This publication and oar other research activities can only continue through your support. Our greatest thanks goes out to those wf you who haue already contributed. This issue nf THE ENAIRONNENTAL GUARDIAN was only possible through your generosity. H special thanks to vne SUFFER member from Laurel, Montana, and another From Minneapolis, Minnesota, who both contribwted $100 to help SUFFER's efforts. LET'S GO TO THE FAIRl Want to help spread the formaldehyde word to unsus- pecting citizen consumers in your area? See about getting a small booth at the Fair (or join a friend in his/her booth). Contact the National GAFFER Coordinator for details and supplies. Let's inform other fanilies who nay be living in a home leeching formaldehyde that their health deserves a better environment. line-year-old J.S. says, `Let's have our SUFFER booth neat to those people who sell that insulation junk.' * MANOFOCTURERS SPEAK UP Do you have an answer to this prA51AAfIOtAA/~ a manwfacturing process which can eliminate the problem of off-gassing of formaldehyde? lIe are waiting with many potential custnoers to hear from you. * Thanks goes nut to David Stevenson, Colorado Attorney General, who petitioned CPSC to lomb into the fawn insulation problem, * Thanks also to Eileen Schell and Barbara llewman of the Massachwsetts Consumer Affairs Oepartnent for all their work and concern in trying to help formal- dehyde victims. 63 TV 4 LARRY SCHMIDT TELLS IT LIKE IT IS: Larry is a very concerned mews reporter who has done much to publicize the plight of formaldehyde victims. We here in Minnesota are very fortunate as Larry is an Investigative News Reporter with WCCO-TO in Minneapolis. Larry has been investigating farmwldehyde reports for about two years, his files are eatensiwe, about 100 cases. He has assisted fanilies in relocating when forced fron their home. He has informed new owners of mobile homes that the previous owners had health problems due to formal- dehyde leeching (the leeching of formaldehyde was not disclosed to the new owners by the dealer). He has also done interviews with Dr. Hugh Westgate of Children's Health Center, who has done ouch to help victims. He has covered all the local, state, Federal and legislative hearings on formaldehyde (his extensive records were used in federal testimony). WCCG-TA again toob on a great financial conimit- ment when Buffy Stone and Art Roy were sent to Oregon to cover the Federal CPSC Hearings and interview formaldehyde victins, Larry also covered state hearings in Wisconsin, Larry graduated from Kansas University and received his masters degree from the Oniwersity of Nebraska, Omaha Campus. Prior to joining WCCO-TU he worked with KDKA-TU, Pittsbarg; Indianapolis TO; and WOW-TV and Radio in Omaha. If it wasn't for Larry Schmidt, SOFFER and THE EHUIRONMEHTAL GUARDIAN would be non-enistent and many families would still be in their fornaldehyde- cvmtaninated homes. The entire staff of Action News went above and beyond their call of duty, Thanks Larryll! CONNECTICUT UPDATE Recently the Federal Consumer Product Safety Commission (CPSC) held four hearings in different areas of the country to gather infornatian on formaldehyde. On February 26, 1HWO, Al and I testified in East Hartford, Connecticut. I testified about our fanily's experience with formaldehyde poisoning from our 0-F foam insula- tion and my subsequent research into the health effects of this toxic chemical, and Al testified as the eastern representative nf SOFFER. We submitted to the Commission references of the abundant anaunt nf research that has been done on formaldehyde and health problens, in- cluding the recent study by the Chemical Industry's Formaldehyde Institute, which showed formaldehyde to be a carcinogen in test rats at 15 ppm. The original tests started at 40 ppm. So many animals died from fnrmaldehyde toxicity, the levels had cv be reduced. (continued on page 13 1 PAGENO="0068" 64 SUFFER IN ACTION Here is a final recap of what was accomplished by many members of SUFFER in the last legislative session. December 15 - A roagh draft of a bill was authored by nenbers of SUFFER and revised by Marc Kurzvan, Attorney for SUFFER. January 10 - A hearing was held by the Sub-covniittee on Health, Lon Heinitz presiding. Testimony was given by many members of SUFFER. The bill was then presented for consideration, linac came sponsors--that's where your calls cane in! House sponsors: Lee treenfield, Gordon Uoss, Adolph Knam, Ion Hbinitz, Peggy Byrne. Senate sponsors: Frank Knvll, Robert Tennessen, terry Sikorski, William Kirchner, Gene Merriam. Many thanks to all of them!!! February 1-15 - The bill went to the Revisors and was given file numbers: House File 02008 and Senate File #2100. March - Hearings were held in the Commerce Committee of both Houses and a compromise kill was approved by the Senate Commerce Committee and sent to the floor. March 28 - Senate File H2100 was passed by am nverwhelvimg majority of the full Senate. April 1 - SUFFER learned that the House version could die as it had been placed on Special Orders 027 of 28 that were to be heard. April 3 - A demonstration was called at the State Capitol Rotunda. SUFFER DEMANDS ACTION!!! April 10 - Tke House Roles Comittee changed Senate File #2100 frov #27 to #3 on Special Orders after an intensiwe lobbying effort by members of SUFFER, at 7:16 p.m. SERATE FILE #2100 WAS PASSED BY IHE FALL HOUSE BYA MARGIN OF 130 TO 4!!! April 11-22 - SUFFER engaged its members in a political opinion telegram campaign to alert Governor Quies office and make the Governor aware of the importance of signing the bill. April 23 - GOUERNOR QUIE SIGNS SENATE FILE #2108 INTO LAW! Secretary of State Joan trowe assigns the bill thapter 594. VECTORS FOR THE PESTLE! With the Governor at the bill-signing ceremony, ,Gpril 2), 1980, were (from left tv right): Troy med Jason Snreceh; Connie Smrecek, Co-Director vf SUPPER; Senatvr Frank Knoll; Joan Dies, SUFFER member; Governor Auto; Carmen Patterson, SUFFER member; Repreeentaiive Lee Greenfield and Steve Patterson, Co-Director of SUPPER. PAGENO="0069" 65 MEDiC ALERT There appears to be a pattern, which we are perceleing here in Minnesota, suggesting a relationship of meurologic dysfunction to euposure of formaldehyde. Do you haoe periods of short-term nenory loss? The following article coy help you to understand the tests available. Neurology, as a subspeciality of Medicine, has developed over the lust century due to the increosing interest in and understanding of brain development and function. In the not-so- recent past neurologists were quite limited in treating nost common meurologic diseases such as strokes, seizures, muscle disease and brain tumors. lecent scientific advances, however, hove greatly expanded our knowledge of brain function in both normal and disease states. Basic research in brain development, such as meuroembryology and genetics, is providing in- creasingly valuable information regarding the fundamental mechanisms through which the human brain grows and is organized and what early influences, even before birth, nay affect its development. The neurological examination consists of a series of clinical tests of intellectual, motor and reflex function that allows the neurologist to localize the anatonical areas of the nervous system that nay be involved in a particular disease process. Abnormalities of the reflexes, for example, may point to either a peripheral problem with the nerves and muscles or reflect a mere central difficulty in thy brain itself. To further define the area involved, certain tests can be obtained which nay measure brain famctian or further define brain structure. The electroencephalo- gram, tEa, is a measure of brain electrical function and is most helpful in defining seizure or convulsive states and in the assess- ment of brain functioning in patients suspected of having toxic insults to the nervous system. The EtA is obtained from electrodes placed on the scalp which are connected to a machine which magnifies the electrical signal elicited from the varioux areas af brain underlying the electrodes and then provides a measurement on paper that can be compared to normal valves. There are, however, linits to the usefulness of the EEG and other procedures are often necessary; mast recently, the CT Brain Stan (compvterized tomographic) has been used to actually denonstrate the internal structure of the brain. The CT scan provides a very de- tailed lnok at the human brain with the ability to define anatomy down to 1/0 of an inch; this can denvnstrate brain tumors, blood vessel abnormalities (aneurysms), and congeni- tal lesions such as cysts. The test is very easy on the subject and safety is a major benefit. Older neurologic tests such as the pmeunoencephalogram iv which air is directly injected through the spinal canal into the brain, are much more dangerous and require hospitalization. Arteriograms, injection of dye into the cerebral blood vessels, are still necessary in many patients bat there is an increased risk compared to the CT stan. Other tests include the EMS )electromyogram) which measures electrical activity of nerves and nuscles through a needle placed directly intn the muscle and Myelogrons in which dye is injected into the spinal canal to demonstrate the internal structore of the spinal turd. With the use xf sophisticated tests, more knowledge is being gained regarding the toxic effects of various chemicals and other agents upon the nervous system of human beings. Mercury, for example, is a known toxin to the fetus when the pregnant mother has ingested small amounts that may not actually affect the mother herself. How many other common chemicals in the immediate environment may have daliterious effects upon the brain remains unknown although neurologists and others are increasingly aware of the potential danger of tuvicity from chemicals that have previously been thought to be safe. More research is needed to define the hazards within the envir- onment and deal approprvately with the in- dividual and social costs involved. John T. MacDonald, M.D. Pediatric Neurology Editors note: Dr. MacDonald of the Minneapolis Clinic of Neurology and Psychiatry is one of the physiciann nn:u resevrcui ng the extent xl harm caused by fnrmaldehyde. NEAT ISSUE SOs this newsletter is going to press, Professor Peter A. Oreysse, tepartnent of Environmental health, Sniversity of Washington, said hed be happy to be r0~v~t~~d Look for acre information in If youd like a copy of the National Atadeny of Sciences assessment of the health effects of formaldehyde, write to: Office of Secretary, CPSC, Washington, D.C. 2O2O~ or call 1-000-332-5403. PAGENO="0070" 66 WHAT DOES CHAPTER 594 DO FOR US? Briefly, it does three things. 1. I, Steve Patterson, as a member and co-founder of SUFFER, feel that the one most important rule the bill sets is this. If a housing unit or building product is found to tontain formaldehyde in significant amounts, and the consumer can medically document that this formaldehyde is causing health problems for him/her, the manufacturer of the product would then be required UNDER THE LAW to pay the `reasonable cost of repair or relocation" to the consumer within 30 days of original presentation of the required documentation. 2. Ut orders the Commissioner of Health to set standards as soon as possible. 3. Um January 1, 1980, it orders industry to make the following disclosure: "WARNING. THUS PRODUCT (COUSINS UNIT) CONTAINS THE CHEMICAL FORMALDEHYDE. FOR SOME PEOPLE FORMALDEHYDE MAY CAUSE HEALTH PROBLEMS, SUCH AS IRRITATION OF THE EYES, NOSE AND THROAT, SNEEZINU, CDUUH- INS, HEADACHES, SHORTNESS OF BREATH, OH CHEST DR STOMACH PAINS. CHILDREN UNDER THE USE OF TWO, ELDEHLY PEOPLE, PEOPLE WITH BREATHING PROBLEMS OR PEOPLE WITH ALLERGIES MAY HAYE MORE SERIOUS DIFFICULTIES. IF YOU HAVE QUESTIONS ABOUT PROBLEMS YOU HAY HAVE WITH FORMALDEHYDE, CONSULT A DOCTOR." Copies of Chapter 594 are available by sending $1.04 to: Documents Section, Centennial Office Building, St. Paul, Minnesota 55104. Be sure to refer to Chapter 594, * NEOT ISSOE - Ue will publish the names and addres- ses of Government Agencies who want to hear F rem you. We request the input of oor readers so that we may keep everyone informed. Please send names and addresses of your local Health Departments and others in your area who can help those with for- maldehyde problems. * THINKING OF HAVING YOUR HOME FOAMED??? Contact your State Health Department indicatinl to them what the materials are that will be used. Advise your State Health Department that if they are not knowledgeable to contact the State Health Depart- ments in the states of Hinnesota, Hisconsin, Rassachusetts, Colorado. Hill the installer guarantee that you will have no ill side effects from the off-gassing of formaldehyde? If so, ask him to sign a statement stating such. * Our thanks to Dr. Alfred Frechette, Conn,issioner of the Massachusetts State Health Department, for banning foam insulation in that state. Also for his deep concern for the health of the citizens of that state. We feel it was because of this ban that 6 CPSC was forced to do something about formaldehyde. = A STEP IN THE RIGHT DIRECTION -~ As oath of us has interacted with traditional health care systems, we have been told repeated- ly that the symptoms we brought to health tare professionals were not related to formaldehyde and, in fact, suggestions were made with respect to vir- taally all of us that we were complaining because of some psychological disorder as opposed to having a "real" problem. Various agenties in the Federal Government have been "studying" this problem of formaldehyde for at least the post three years, yet, no government agency has yet teme out with specific standards. lie should be hopeful, however, as recently the No- tional Academy of Sciences, on special contract to the federal government, conducted an overview of the research data surrounding formaldehyde and con- cluded that there is "no safe threshold level for the general population," Through the efforts of physicians, attareeys, neus- people and, most importantly, we consumers, there has been activity mounted in a number of states. In Rassathusetts urea-formaldehyde foam soles are bummed absolutely; in Connecticut there is an agreement between the Attorney General and the urea foam insulator manufacturers with respect to processes for insuring the safety of individuals using this material or having it installed in their home; Minnesota's bill is discussed in another section of this newsletter; in disconsin the State has set regulatory mauinum levels of formaldehyde to go into effect over the moot year. Us more information has been collected, there has been a significant increase in the number of medi- cal and other related professionals who have found causal relutianships between formaldehyde exposure and various Illnesses and occasional deaths. How- ever, we can only come to understand the full ex- tent of possible medical harm by comparing problems we, individually, have suffered to Eke information of medical researchers. In the next few months, data on 0000 families should be released from the Oniversity of Hashingtom. He will attempt to sum- marize that and include that summary in the meot newsletter, It is important, however, both fur the Vniversity of Washington researchers and ourselves that full medical information is discussed. Therefore, we have set forth a list of symptoms (see question- naire) suffered by members of SUFFER with which there is enough scientific and/or medical data guthered to suggest a causal relationship. This list is not meant to be inclusive and we would appreciate your sending information relative to the items set forth and include any other symptoms/ tests wMch we have not induded. @~ PAGENO="0071" 67 Court name: Address: * Attorney's name: Address: * Dealer's name: Address: - QUESTIONNAIRE -- Telephone So.: _________________________ * Physician's name: Specialty: Clinic name: Address: able in the area of formaldehyde? __________________ * Physician's mane: Telephone No.: _________________________ Are you satisfied with the help you've received from the dealer: ____________________ * Manufacturer's name: Address: Telephone No.: _________________________ Are you satisfied with the help you've received from the manufacturer? _______________ Has the manufacturer admitted to a formaldehyde problen? * Air testing for formaldehyde: Date Level Done By * Physician's name: Specialty: Clinic name: Address: _________________________________________ Telephone No.: _________________________ Are you satisfied with the help this physician has given? ______________ Is the physician knowledge- able in the area of formaldehyde? SUFFER would appreciate receiving information on suspected health difficulties associated with formaldehyde so that this might be shared with physician counsels and researchers in am effort to determine the eatent of harm caused, Many of these appear Co be frequent symptoms. SUFFER is not reconmending tests be taken, but is interested in gathering data. Please complete this questionnaire and return. * Are you contemplating a lawsuit? _________________ *Victin's name(s): ______________________________ Have you settled out of court? _____________________ Occupation(s): _____________________________________ Case settled in court? ___________________________ Address: _________________________________________ Case No. _______________ Date: __________________ ___________________________________________ Telephone Na.: Telephone No.: ________________________ Would you recommend your attorney? Are you satisfied with the help this physician has given? ________________ Is the physician knowledge- Specialty: - Clinic name: Address: Telephone No.: _________________________ Are you satisfied with the help this physician has givem? ________________ Is the physician knowledge- able in the area of formaldehyde? ________________ 5. List any corrective action taken to lower the reading: © coeyniaa~cs BY SUFFER REPRINTED DEtERRER 1981 PAGENO="0072" ~________ ft ~ I ~H~HLHU H~ I F W I PAGENO="0073" PAGENO="0074" 70 is FORMALDEHYDE POISONING YOU AND YOUR HOME? ~ I, ~ IN A NEW HONE/BUILDING OR IN A MOBILE HOME/UNIT OR IF YOUR HONE/WORK DEVIRO?ORENT CONTAINS UREA FORMALDEHYDE FOAM INSULATION (UFFI) PARTICLE BOARD PANELING PLUNDOD CARPETING OR IF YOUR OCCUPATION EXPOSES YOU TO PRODUCTS CONTAINING FORMALDEHYDE, THAN: YOU TOO MAY BE A VICTIM OF FORMALDEHYDE POISONiNG When you first learn that formaldehyde has taken over your hove, you probably feel like the only person in this world that this has happened to. WRONGI Hundreds and hundreds of people Proc the United Stateo and Canada hove con- tacted national SUFFER headquarters. National SUFFER reoponds ho between 2 and IS phone calls and Setters daiSy. We feel that everyone is affected by formaldehyde to some degree, they just cay not be aware of it yet. YET is the hey word. Will it happen to them next week or will it take another year or two? It teak one famSly two yearo to learn that fsrealdehyde was in their home. Another family lived in their home for almost oeven years before they tee learned that formaldehyde had contaminated their home and their bodies. When will you thou it has happened to you too? YOU CAN BE AFFECTED WITHOUT EVEN KNOWING YOU ARE I! EARACI8ES CONGESTION DEPRESSION NAUSEA, VOHITING SORE, STREP THROAT COUCHING EI0AAUSTICN IRRITABILITY FLU-LIRE SYMPTOMS RUNNY, BLOODY NOSE DIARRHEA SCO RASH RUNNY EYES ASTSBCALIKL SYMPTOMS HEADACIGES RAMP MANY, NARY OTHERS AS WELL AS POTENTIALLY CAUSING INFANT DEALING (SIRS) RID CANCER EVERYONE IS AFFECTED TO SOME DEGREE WHY DOES SUFFER NEED YOU??? WE NEED YOUR FINANCIAL SUPPORT AS WELL AS YOUR MORAL SUPPORT. IF YOU HAVE FOUND SUFFER TO BE HELPFUL VIA TELEPHONE PERSONAL LESTER NEWSLETTER MEETING ETC. PLEASE CONSIDER THE COST TO US IN OBTAINING THAT USEFUL INFORMATION AND THE TIME THOSE VOLUNTEERS ARE SPENDING WISH YOU. SUFFER CANNOT CONTINUE HELPING YOU AND OTHERS WITHOUT MONEY TO PAY THE BILLS. S U F F E A I S E X P E R I E N C I N G FINANCIAL DISASTERI 5) pear eec a cse'Otsa,t as. masse psbli.A ass peer (4 i.,aas) ee c,aeE.tser,. Ths5 peer ta. sca.d. sores ha. ,sseau outset. .reea tt: ~x1d. a, hear 5oe. h.ipbA as Hoe beeo Ass sest eaoslA.. f.,t tbsp c.econ .eeud so sill cutlass patli.t(og The toelre.moetai OusrdA:o. a. n~. to (salad, .atic(,. rsi.tiug tc: \ Same Us From Formaldehyde Envlruomeotal Repercuaslona .~\9P~) ~4~) SEND MERBERSS1IP DONATION TO: SUFFER, INC., RRIA, BOX 148C, WACONIA, PD) 55387 (612) 448-5441 o ~.0o enclosed for issue #1, June ~ $U.0O enclosed for issues #2 & 3 D DU.SO enclosed for issue #4, October 19s0. Includes: SUFFER's Victie (combined), Febuary 1981. Includes: 1981. Includes: SUFFERs Incident Health Questicesaire (4 pgs. of CuT Report on Formaldehyde as a Report (share with attorney/physician/ vital data includisg henlth syee- Carcinogen, Formaldehyde and SODS, teacher/SUFFER), Mobile Hone Condemns- truss, e tensive list of products Has Your Mobile Hose been Recold, tion, Legal Ledger (Litigetion Group & containisg formaldehyde & "Medid Testing Levels, Flier (pest me) HENO Court Case), Alternate Naves for fore- Allert", seurologic info, end Your Being. aldehyde, Prof. Breysse's Review. CURRENT NEWSLETTER (4 ISSUES YEARLY) AND MCI4BERSNIP DONATION INFORMATION ~ Individual/fasi~y 820.00 (= SUFFER members are helped by star __________________________________- ~ Professipsala 850.00 leg information, if you prefer re- race ~ Sprussve~Jsip $100.00 or eore meAning anonymous check bee. _____________________________ ~ Victiss ask SUFFER fom a list of ti~El~ SUFFER eeeJeers who are medical! ____________________________________ legal professionals who ore knasa- addbeen ~ I'd like to be a SUFFER Coordinator ledgeeble shout formaldehyde. __________________________________ for er1' state. Clseck box if you would like to be city/state/zip ~ I'd like to sosist ej state SUFFER included & send letter stating _____________________________________ Coordinator, expertise, area code/telephone a PAGENO="0075" 71 CIGARETTE SMOKE OFF-GASSES 30-40 PPM FORMALDEHYDE * The following article was written by Mena Sprague, Nebraaha SUFFER Coordinator. Mona has been forced to live the life of a recluse for over two yearo due to her hypersensitivity to formaldehyde. Dave and I had svoked cigarettes for around 20 years each when we had to decide whether our love for each other and our love of life was stronger than our addiction to cigarettes~ We thank God that He gave us the strength to win one of our nost difficult battles. To help you prepare yourselves for the upconing battle, here are a couple of quotes fron Why Dick Can't Stop Smoking', Mother Jones, January 1979. 1. Former drug addicts and alcoholics who have been surveyed consider its harder to give up tobacco than heroin 2. The former director of hEW's National Institute on Drug Abuse, Dr. Robert Dupont, estimates that only 10 to lb percent of the people alive today who ever use.! heroin are still addicted, where as ogre than 66 per- cent of those still living who ever smoked cigarettes are currently daily 3. Chemically and pharmacologically, nicotine is related to such central nervous system stimulants as methylphuri- date and the amphetamines, which are even more addictive than heroin and other opiates. 4. Both drug and alcohol addicts can toler- ate drug-free periods, where as only 2 percent of all cigarette users are intermittent smokers. First of all prepare yourself and those you live with for the upcoming battle, and ask for their support, understanding and patience. You will be going through extreme changes mentally and physically. Then pick a due date, the day you are going to smoke your last cigarette, ours was March 31, 1976, or we say we quit on vpril Fool's Day. Imediately start cutting down and delaying the first cigarette of the day. If your first cigarette is before or after breakfast, delay it until your first break at work. After a couple of days delay the first cigarette until after dimmer, then mid-afternoon break, then supper, them to bed-time,. If you can delay your first cigarette to just before bed-tine, you should at this point be ready to quit. For hard core addicts like Dave and myself, we suggest the final might before your due date you smoke yourself sick. From supper on we chain-smoked until bed-time. Do not use a low-tar cigarette for this. Now for the hard times, you must flush the nicotine out of your system, so drink plenty of water and fruit juices. There are certain foods that enhance your need for nicotine so stay away from them the first week. They are: coffee, alcohol and highly spiced foods such as pizza. Refrain from going to bars and other smokey places, and if possible, don't associate with friends who smoke until you are more comfortable with not smoking. Replace ash trays with thanks for not smoking signs available through the Lung Association or the Cancer Society. Keep yourself busy during what used to be your smoking time. Dont gorge yourself with food or junk food, if you feel you must have a pacifier, chew sugarless guy. We gained about 10 pounds each, and after our systems had stabilized in a couple of months we returned to our normal weight. The buddy system is also helpful. Keep a positive attitude towards not smoking, notice how fresh and clean your house and car now smell. A whole new world of smells and tastes are awaiting you. Notice how all smokers smell as though they need a bath and even strong perfume can't cover that burned smell. Remember your home is your castle and you do have the right to ask people not to smoke in If you don't succeed the first time, don't be too hard on yourself and learn from your mistakes. Set another due date and start over again. Know that you have improved your health by not smoking. We had am argument about 3 months after we'd quit, so Dave smoked 3 cigarettes in 6 hours at work, first he started vomiting then dry heaving. WAco he came home he told me, `1 used to think I quit snoking for you, mow I know I quit for me.' All American cigarettes contain at least 3 known aldehydes--formaldehyde, crotonaldehyde and acrolein, If you are bothered by particle board, plywood or foam insulation, the formaldehyde in your cigarette will soon affect you in the sane way. I'll leave you with another quote from Mother Jones, per Dr. Altom Ochsner, surgeon and seni or consultant to the Ochsmer Foundation Hospital in New Orleans; Ome thing he has noticed, after a half-century of comparing men patients who smoke with those who do not, is that abstaimers have had better sex lives and fewer cases of impotence or low sperm count than their nicotine-addicted counter parts. We overcame it and so cam you! Editor's note: Steve and Carmen Patterson learned how to stop smoking following Dave's advice. Our thanks to him and Mena. * LET'S HELP OTHERS! 11 PAGENO="0076" 72 I'M MAD AS HELL AND I'M NOT GOING TO TAKE IT ANYMORE! I'M MAD AS HELL ANO PM NOT GOING TO TAKE IT ANYMORE! I'M MAD AS HELL AND I'M NOT GOING TO TAKE IT ANYMORE! 1. I am going to call CPSC (Consumer Products Safety Cxnnnissinn) in Washington, D.C., at their toll- free number (1-800-638-8326) to file a formalde- hyde complaint, even if I've already done so. Our messages have to reach them before July 14, 1980, when they make their decision. 2. I an going to tall or write my local CPSC and State Health Deportment and file a formaldehyde complaint with then. 3. I am going to call or write my local newspapers urging them to print articles on formaldehyde. I'll also call or write thanking them for articles published. 4. I am going to call or write my local radio sta- tions urging them to broadcast more on formalde- hyde. I'll also call or write thanking them each tine I hear a broadcast. N. I am going to call or write my television sta- tions urging them to broadcast more on formal- dehyde. I'll also call or write then thanking them each time I see reports. 6. I am going to write my Representative and Senator eoplaining to them the formaldehyde problem. He/she can only enact legislation after they know of problems. Addresses are available at ny library. 7. I an going to write a letter to the President of the Onited States (see letter in following article) and send copies of it to the various places shown in the Newsletter. 8. I am going to be my STATE'S SUFFER COORDINATOR or help her/him. 9. I am going to ask if any building materials that I may want to buy contain urea-formaldehyde. If It does, I will refuse to buy it, then I'll write the manufacturer and tell them so, OREGON UPDATE Many Oregon families are looking foeward to be- coming an active branch of SUFFER. Some of our present projects and future objectives include: 1. Compiling a list of knowledgeable physicians who have dealt with formaldehyde toxiclty/ 2. Establishing mare easily accessible and in- expensive formaldehyde testing facilities. 3. Encouraging energy-conscious institutions such as Oregon's PGE and Seattle City and Light, to scrutinize the intrinsic hazards of urea- formaldehyde foam insulation. 4. Eventually, working with the Oregon Oepartinemt of Health, Disease Control Division, to find suitable relocation sites for formaldehyde victims, as the states of Wisconsin and Massachusetts have already dome. N. Influencing legislators and goverement officials to regulate (and/or eliminate) 12 formaldehyde exposure. Currently, we are also in contact with nany occupa- tionally-exposed individuals and encourage them to participate in SOFFER. We are watching closely two sepurate Oregon law suits filed against: 1. Bendix Hone Systems, Inc., a mobile home manufacturing firm, and 2. Comfort Foam Insulation, Ltd., of Salem and SI Formulators, Inc., Hillsboro. We have also contacted the Oregon Chapter of SIOS (Sudden Infant Death Syndrome). Three infant deaths have recently occurred in mobile homes in Oregon. Hope- fully, future studies measuring formaldehyde levels involving exposed infants will be instigated. Footnotes: The Department of Comerte of Oregon, Mobile Home Division, will test for formaldehyde levels when specifically demanded, for a fee of approximately $20. However, the instrument they use is a BENDIX gastec, and more valid testing instrumentation is necessary. The Oregon CPSC cam borrow equipment from other agencies but the red tape required, adds up to months of delay. Peter Breysse will be coning to Oregon the latter part of June to test the Kelley mobile home. We encourage others to take advantage of his presence in our During the surner of 1979, we sent out questionnaires to exposed Oregonians who have filed cvoplaints with the state. At that time, our lawyer advised us that because of the many different manufacturers involved and the myriad range of consumer complaints, a class action suit would vot be possible. However, the Washington law firm associated with J. Kathleen Learned, has received several inquiries from formaldehyde victims, and they are looking into the feasibility of a class action suit. Presently they are representing veterans exposed to agent orange. We have observed that when consumers find themselves eoperiencimg ill health because of formaldehyde exposure in `~. r own hones, a series of predictable steps usuallj er:sxes: The imdividuals themselves first react with utter disbelief. The threat of possibly losing one's home is basically a threat to survival, since shelter is a necessity of life. Eventually, however, deteriorating health becxmes a more basic threat, rendering the affects of exposure impossible to deny. The next step in this process involves extricating oneself from the environment if at all possible. This usually takes place under at least three false premises: 1. The individuals feel they are uniquely the only people affected in this manner and/or 2. They feel previous allergies negate the harmfwl affects of formaldehyde and 3. They feel there are no long term consequences. All three assumptions are wrong. We find it amazing, and, at the same time, ~ joo.. that alnost everyone we talk to has a friend or relative coming in contact with formaldehyde and experiencing adverse symptoms. The problem is simply mushrooming and industry knows it. The rumor here in Oregon says that the Formaldehyde Institute is gearing up a momentous advertising campaign to inform Americans of the necessity and usefulness of formaldehyde. It is imperative that we help others who are experiencing crises that we have already gone through. It is imperative we joim together to write to and influence our governmental represemta- As a mother, I find it totally incomprehensible that any parent who has had a child suffer from formalde- hyde exposure, would not do ull~ltA(n their power to prevent other children from experiencing the same fate. vy Nuvmi KeXXay, Oregon wrFEv Coordinator PAGENO="0077" * (continued) There is a very important factor that has to be considered. The tests were run for only 6 hours a day, 5 days a week. Tests to accurately show the effects of home exposure would have to be run for 24 hours a day, 7 days a week. This would be the exposure for infants, preschoolers, pregnant women, the sick and elderly, all who are least likely to be able to tolerate formaldehyde There have been reported a number of deaths of infants from formaldehyde. We feel eventually it will be shown that formaldehyde is a major cause of Sudden Infant Death Syndrome (SIDS). We strongly feel that there should be stringent levels put on the amount of formaldehyde allowed in the indoor environment. There are levels for workers in industry but none for the home. Russian indoor levels of formaldehyde are set at .01 ppm. The U.S. Governments NASA has set levels for manned spacecraft also at .01 ppm.. It should be noted this is for healthy 150 pound men, not snail infants. Formaldehyde is especially dangerous because it is a sensitizer chemical, which is not true of mast other chemicals. A ouch larger prmportion of the population is sensitized to formaldehyde than realizes it. Most children and adults who have `allergies also have problens with products con- taining formaldehyde. In many cases it appears that a child's so-called allergies began with sensitization to formaldehyde. If a simple test could be devised to easily detect those sensitized to formaldehyde, the results would be alarming. For evample, anyone who has problems with cigarmtte smoke is probably sensitized to formaldehyde, as it is the cause of eye and respira- tory problems from smoke, Recent research is show- ing it is the aldehydes in cigarette smoke that are responsible for its cardiovascular damage. In April, Al testified in Ooston before the Massachusetts State Legislature's Health Coonnittee at the request of the Massachusetts Consumer Affairs Department. Industry is trying to overturn the ban of U-F foam insulation invoked by the Massachusetts State Health Comissioner, Dr. Frechette. The Federal CPSC has received over 600 complaints about formaldehyde causing health problems ranging from allergies to death, resulting from evposurm in foam insulation, mobile hones, wall-to-wall carpeting, pharmaceuticals, particle board and other building supplies, etc. The CPSC is re- searching the problem and would like to hear from anyone who can help them. Their toll-free number is: 1-800-638-0326 and doesn't cost anything to Ask then to send you some of the information they have on formaldehyde. Also, request a copy of the National Academy of Sciences (HAS) Report on Formaldehyde. This was a study sponsored by the U.S. government to find a reconinended safe level of formaldehyde for the home environment. After months of study, the HAS concluded there is no safe level for formaldehyde. It is important to avoid this sensitizer chemical as much as possible, so we should let the gonermment know we don't want it in our products. Uy Carol Palinero, Connecticut SUFFER Coordinator 73 Rerderm:~~G The mailbag reserves the right to publish letters on it's own discretion. We maintain the right to publish any letters unless you specifically request us to withhold it. We respect your right to pri- vacy and will not violate that. However, many want to know about your experience so send it to mail- bag. Signed, Mailbag Dear SUFFER., I read your article in our daily paper and heard of the formaldehyde problem, as we anticipate a rather large remodeling project this suniner, I took this concern to our prmspective builder. He bluntly told me he would not spend any time checking it out-regarding his materials. Needless to say we canceled our intentions to use him as our builder. I have found that no one in this area is aware of the problem, The lumber companies, even apprm- priate persons at City Hall are ignorant of this problem. It was truly a relief to see your arti- cle. Hopefully, with prudent judgment in selection of materials, we can avoid this hazardous problem. Please send me whatever information you can. If there is a fee, please include that also. I am truly thankful to you for taking a stand and making this public so others can be helped. Signed, disconsin Rapids, Wist. Dear Wisconsin Reader, We are thankful that our message of formaldehyde problems has reached you. We can now say at least one family has been spared the suffering others were subjected to. At this time the only swgnos- tions we can offer are: 0. Continue to seek a builder who is receptive to your concerns. And don't let then mislead you. Formaldehyde problems have been publicized in their trade journals for some time. 2. When doing remodeling we suggest that you go with real wood. That is, avoid particleboard that contains Drea-Formaldehyde. Instead use either plywood or the new type of particle board which uses Phenol-Formaldehyde as a base, For vbsolute peace of mind, exterior grade plywood is the safest bmt, but a good trustworthy builder should be able to well advise you. EDITOR'S NOTE: SUFFER. solicits knowledgeable advice from the lumber industry in assisting us to answer such inquiries as the one above. Signed, continued SAFFER PAGENO="0078" 74 * HAVE YOU EVER WONDERED WHAT PRODUCTS OTHER THAN BUILDING MATERIALS CONTAIN FORMALDEHYDE? BATTELLE'S FINAL REPORT ON FORMALDEHYDE FROM CPSC Particle board, U-F foam insulation, vet strength paper such as wax and butchers, perma press cotton, plastic, plywood, molding compounds, binders for fiberglass and mineral wool insulation, formica, pressed wood furniture, brake drums, plastic parts for vehicles, plumbing fixtures, hardware, lawn and garden equipment, sporting goods, counter and table tops, melanine tableware, resins and oil based paints, explosives, vinyl resins, electrical insulation parts, nitrogen fertilizers, phenolic termasetting resins, tire rubbers, insecticides, pharmaceuticals, textile treating agents, detergents, water softening chemicals, some fertilizers, urethane coatings and resins, antihistamines, aerosol insecticides, dyes for textile industry, embalming agents, mascara and other cosmetics, barber and beauty shop dis- infectants, farmers spray on animal feed to stop bacteria growth, air freshners to reduce the sensitivity of one's sense of smell, dry cleaners for disinfectant, fiber board, air and furnace filters, furniture adhesives, binding on paper bag seams, plaster of Paris castings, orthopedic casts and bandages, binders for sand foundry cores, coated papers used for cartons and labels, coatings for appliances, primer coats for auto- mobiles, paint and wood finishes, housings for electric shavers and mixers, electronic equipment, soap dispensers, stove and refrigerator hardware, toilet seats, knob and buttons, utensil handles, shampoo, nail polish, mildew prevention, synthetic lubricants, textile water-proofing, preserving flour, wheat grains and agricultural seeds, facial tissues and napkins, disposable sanitary products (hospital bed sheets, examining table paper rolls, dental bibsand diaper liners), some filter papers, rayon, drapery and upholstery fabrics, latex for carpet and upholstery backing, non-woven binders and flock adhesives, softeners and lubricants, hand mxdifiers, flame retardants, anti-slip agents, antistatic agents, bactericides and napping agents and sanforized cottons. BOOK REVIEW: The following books may help you understand hyper- sensitivity to formaldehyde and other chemicals. The books may be available at your local library. 1. HUMAN ECOLOGY AND SUSCEPTIBILITY TO THE CHEMICAL ENVIRONMENT by Therxn Randolph, M.D. It can be purchased by sending $11.50 to Charles Thomas, 327 Ewst Lawrence, Springfield, Illinois 62700. CHEMICAL INDUSTRY INSTITUTE OF TOXICOLOGY Leather tanning, preservative, preparation of vaccines, axtonvtive exhaust, off-gassing from products derived from formaldehyde peroxides and hydroperoxides, water filters, anti-perspirant formations, oral hexanethylemetetranine medi- cation, drinking milk, dental filling, dust sterilizing solutions, hair vaving preparations, shampoos, deodorants, nail polish, nail hardener, glues, many teotiles especially of cotton and rayon, paper products, orthopedic plaster casts, vaccines, acrylic, wool, rayon and nylon fibers, photo chemical smog and cigarette smoke. AREA AND MELAMINE RESINS 55.6% used in bonding particle board, 10% used for laminating such things as veneers, 9% used for plywood manufacturing, 11.6% used for molded plastic goods such as buttons, dinnerware and electrical fittings and 5% to 6% goes for coatings and treatments for textiles, paper products and protective materials such as paints. PHENOLIC RESINS 30t plyuond, 39% bonding, adhesive and laminating uses such as abrasives, particle board, friction materials (brake linings), foundry molds, insulating materials (fiber glass), electrical insulation and numerous other molded plastic components. Editor's note: Our special thanks to our Nebraska coordinator for collecting this data. * (continued) Bear XC. California, We are concerned about your problems and are happy you found a doctor who knows what you are talking about. The symptoms you and your family are ex- periencing are connmn to others with formaldehyde problems. He would like to know more about your experiences and are hoping for a successful solu- tion. Please share It with all of us. Mailbag 2. MANAGEMENT OF COMPLEO ALLERGIES by Natalie Solos. TYiifbi purchased by sending $8.95 to Mrs. Gladys Holst, 1019 West 3rd Street, Red Wing, Minnesota 55066. Can you reconenend any books on the subject? SORTER RB IA, BER 148C WACONIA, me 0S387 ADDRESS CORRECTION BECOJESTEO v;xte(~~ ~R~)/ FIRST CLASS PAGENO="0079" 75 ~` S.U.F.F.E.R. is a grassroots non-profit organization of families exposed to formaldehyde joining together, dedicating themselves to helping you. Our goal is to educate the public on the hazards of formaldehyde so that others might be spared the SUFFERing they themselves have endured. The ABC `20/20" formaldehyde segment brought national attention to a problem SUFFER has been working on for years. We are a national organization (as well as having contacts in Canada, and overseas) with chapters in thirty states. Our workers volunteer their time and have been using family funds to support their work. We want to help you also. If you find that SUFFER could help you, or have already found SUFFER helpful via letter, phone call, etc., please consider the cost to us in obtaining that information and the time those volunteers are spending with you. Our time is in demand and we can only release our information to members who are willing to support us. By joining SUFFER, we can help you find medical and legal professionals who can aid you. We keep you up-to-date on publications, programs and events. The Environmental Guardian, SUFFER's newsletter, is published quarterly to answer your questions and give you information regarding: HOW TO BUILD/RE-CO YOUR HOME MEDIA EVENTS SPECIAL PROBLEMS OUR CHILDREN DEVELOPE LEGAL LEDGER STATE AND INTERNATIONAL UPDATES BOOK REVIEWS INTERVIEWS WITH MEDICAL PROFESSIONALS CARTOON CONTEST INTERVIEWS WITH LEGAL PROFESSIONALS ROTATION/ORGANIC DIET QUESTIONS/LETTERS TO THE EDITOR SUFFER'S VICTIM HEALTH INFORMATION ON CLASS ACTION LAWSUITS QUESTIONNAIRE REFERENCES FOR MORE INFORMATION SUFFER'S INCIDENT REPORT FORMALDEHYDE POISONI NG EVERYONE IS AF~ECTEO TO SOME DEGREE YOU CAN ~E AFFECTED W'THO EVEN KNOWING YOU ARE I! POSSIBLE SYMPTOMS INCLUDE: Headaches Flu-like Symptoms Collection of Fluid in Lungs Dizziness Asthma-like Symptoms (pulmonary edema) Coughing Weight loss/gain Inflamation of the Lungs Earaches Disturbed Sleep (pneumonitis) Skin Rash Abdominal Pain Upper Respiratory Irritation Irritability Tightening of Chest Inability to Handle Stress Nausea, Vomiting Burning of the Eyes Sensitization to Formaldehyde Sore, Strep Throat Tearing of the Eyes (as well as other chemicals) Runny, Bloody Nose Sense of Pressure in Head Food Allergies Memory Loss Palpitation of Heart Deaths (including Infant Cancer Deaths or SIDS) YOU TOO MAY BEAVICTIM OF FORMALDEHYDE POISONING ~u~1s. S.n U. Fr~ F.r~.Ids~ds~*s...MmI I.psrc...k.. RRIA BOX 148C .AaI~A, )s4 55387 5 (111 PAGENO="0080" 76 FORMALDEHYDE POISONING YOU AND YOuR HOME? Can the air in ay home be tested for formaldehyde gas? Yes, we can put our members in touch with companies that sell testing devices arid kits so you may test the air yourself, or with companies to test for you. Is there a safe level? Our printed materials will help you make an educated decision as to what level you feel is safe. What are some of the building products/materials that contain formaldehy~ti Urea formaldehyde foam insulation (UFFI - U.S. Consumer Product Safety Commission banned UFFI in residences and schools, effective August 10, 1982.), particle board (and other similar wood used in subflooring or underlayment, furniture, cabinets, shelving, paneling or walls), plywood, carpeting, resin treated upholstery, resins, as well as many others. It is also used in many products other than building materials. High levels have also been found in the work place. What are my legal rights? We can help put members in touch with legal pro- fessionals with expertise in the area of formaldehyde who can represent you or assist your present attorney. My doctor doesn't know about formaldehyde. We can help put physicians in touch with other physicians who are knowledgeable in the field. ATTENTION PROFESSIONALS: If you have expertise in the area of formaldehyde and would like to be referred to victims, please send a letter stating expertise. Our volunteers have handled as many as 70 to 200 letters and phone calls per day. In order to continue helping the vast amount of people exposed, we must ask for membership donations prior to volunteering time and information. The majority of questions can be answered in our newsletter The Environmental Guardian See Membership Form If you live/work in a new home/building or in a manufactured unit (including mobile home) or in a remodeled home/work environment or if your occupation exposes you to products containing formaldehyde then you too may be SUFFERing from formaldehyde poisonin~ S.v,U.Fy~E.r118U~ sQ~ ~ aaaTX~ ~ Dc., 8*IA, BOX 148C, WA~8IA, 881 55387 Issue #1, June 1980 Issue #2 & 3, Feb. 1981 Issue #4, Oct. 1981 Includes: SUFFER's Includes: CIIT Report Includes: SUFFER's Victim Health Quest- on Formaldehyde as a Incident Report (share ionnaire (4 pgs. of Carcinogen, Formaldehyde with attorney/physician/ vital data including and SIDS, Has Your Mobile teacher/SUFFER), Mobile health symptoms, Home Been Resold, Testing Home Condemnation, Legal extensive list of Levels, Flier (post me), Ledger (Litigation Group products containing HCHO and your Being. & Court Case), Alternate formaldehyde & "Medic Names for Formaldehyde, Allert", neurologic Prof. Breysse's Review. information. *~****CURRENT NEWSLETTER (4 ISSUES YEARLY) AND MEMBERSHIP DONATION INFORMATION****** - Individual/Family $20.00 Back Issues Available ______________________ to Current Members Only: name - Professionals $50.00 - Issue #1 - $5.00 - Sponsorship $100 or more Issue #2 & 3 - $5.00 title Membership beings with - _________________________ latest printed issue. - Issue #4 - $5.oo address - I'd like to be a SUFFER city/state/zip Coordinator for my state. - I'd like to assist my State area code/telephoi~T SUFFER Coordinator. - I need Legal Referral. - SUFFER members are I need Medical Referral. helped by sharing - info. If you prefer - I need Air Testing Info. ~ ~ remaining anonymous, .1 check here. PAGENO="0081" 77 Mr. ROSENTHAL. Mr. Kurzman, would you like to add anything to this testimony? Mr. KURZMAN. Mr. Chairman, and members of the committee, I can appreciate that this might sound a bit far-fetched. I represent Connie Smrecek in an individual capacity. I also lead a national litigation group where we are coordinating through the Association of Trial Lawyers of America. The story that Mrs. Smrecek is relating with respect to her sensi- tivity is typical of stories relating to sensitivities of clients who have been victims throughout the country. The reality of it is perhaps expressed by the fact that within the last 6 months there has been over $2 million paid or awarded by juries and by way of settlement to people who have complained of symptoms such as Connie Smrecek has related to you. I would think that juries would not make awards and companies would not pay six-figure-settlements were it not based, in fact, not only to the sensitivity, but with respect to the neurological damage. We have had Mrs. Smrecek's children examined by three teams of psychiatrists, psychometrics, and neurologists. Quite frankly I was dubious myself when I first learned about the possibility of the organic brain damage. Unfortunately those three teams came up with the same result, that there is organic brain damage in her children. Dr. Schanker is doing research at Harvard University right now which discloses that among all adults who are exposed to all levels above 0.14 parts per million, there appears to be a memory loss, a neurologic defect. I would suggest to the committee that Mrs. Smrecek's story is typical. The lack or the continued sensitivity extends from formal- dehyde to other chemicals within the environment and perhaps some of the scientists today or tomorrow can explain that to you and how it works. But her story unfortunately is typical. The people that she has been speaking with-about 80,000 in the last couple of months who have followed up since the CPSC ban and since the ABC television show about formaldehyde-suggest that there are people all over the country that are in a panic. They know that they have adverse health effects. They have gone to physicians who have been unable to properly diagnose it. They then have tried to find agencies to help test it. We know that New York State has now agreed to test homes for people. That is commendable; but other States do not do it. So you have victims out there without any possible remedies. They cannot find out how much formaldehyde is in their home. They cannot find physicians that are knowledgeable about the treatment, and they have no recourse but to keep living in the home while they continue to suffer the adverse health effects. Mr. ROSENTHAL. Thank you very much. Mrs. Barth. Welcome; you may proceed. STATEMENT OF MARIANNE BARTH, UFFI HOMEOWNER, COTUIT, MASS. Mrs. BARTH. Thank you, Mr. Chairman. 97-153 O-82--6 PAGENO="0082" 78 My name is Marianne Barth, and I live at 68 Furlong Way, Cotuit, Mass., with my husband Donald and my two daughters, Cynthia and Jennifer. I moved to Cotuit in the summer of 1978, and was really excited about my new one-half underground, energy efficient home de- signed by my husband, when my plight with urea formaldehyde foam insulation begain. In October of 1977, my husband contracted Heat Conservers of Cape Cod, owned by Mr. Paul Killeen of Sandwich, Mass., to insu- late our home with comfort foam. We were advised by Mr. Killeen not to enter the dwelling until 48 hours after installation. A few days later, our contractor called to tell us that the electrician, plumber, and masonry men had walked off the job. He stated he had to open all the windows and doors in order to stay in the house a few minutes. He told us about his burning eyes and sore throat. We contacted Mr. Killeen and he told us to give the insulation a few weeks to cure. After a few weeks, Mr. Killeen tried to remedy the situation by painting the interior walls with a vinyl paint. Donald then papered the walls with vinyl wallpaper, thus install- ing a vapor barrier. At this time, Don developed nosebleeds and a severe sore throat and was treated several times at Falmouth Hospital. On one occa- sion the blood vessels broke in his eye causing the eye to look like a piece of liver. This time he needed to see an eye specialist. My dad, Mr. Hans Wailer, worked in the house a few hours a day putting casing around the windows and doors. In late Decem- ber, he was treated at Cape Cod Hospital for severe nosebleeds and was admitted for 3 days over Christmas. He was 72 years old at the time, and this was a severe shock to his system. In January and February of 1978, Mr. Kiileen put deodorizers around called "Bad Odor Sponge." The crystals turned completely black. In March he rolled poly coupler all over the wallpaper and woodwork. I never set foot into the house all winter. I was terribly upset and could not stand the irritation. I really felt lost, so I called the Board of Health in Hyannis, Mass., and spoke with a John Kelly. He advised me to contact Mr. Michaels at the Massachusetts De- partment of Public Health. I contacted Mr. Michaels, and he told me that I was the first to complain about UFFI and he did not know what he could do. A year had gone by since our move to the Cape, and the efficien- cy apartment we had rented was spoken for so we decided to try to move into our new home. In May of 1978 we moved in and stayed 3 weeks. Cynthia was sent home from school on three different occasions with what the nurse called conjunctivitis. During this time she also had severe nosebleeds and had to have her nose cauterized. Dr. Dewell said she had lost a few layers of skin in her nose. PAGENO="0083" 79 Jennifer was always nauseous and had developed a bronchial cough. I had dizzy spells, severe headaches, and laryngitis. I was treated by Dr. Dewell and was told something was irritating me. I explained the house situation, and he advised me to move out and take my family with me. I then contacted Public Health again, and they sent an inspector to the house. I also contacted WCVB, channel 5 in Boston. At the time they were investigating UFFI for a news special. In June, July, and August, Public Health came several times to try to get readings, but as you all know, heat and humidity affect the reading levels, so each time they came the readings were differ- ent. In August 1978, about 1 year from installation, a Mr. Gray from the National Association of Urea Foam Insulation Manufacturers called me and told me he was sorry about my troubles and would see to it that my home was made livable. Mr. Charles Campbell, Mr. Charles Pesko, and Mr. William Egnor, all from NAUFIM, visited the house and admitted that we had a real problem. Don met with these men on several different occasions, and at this time it was decided that the only solution was to insert poly coupler directly into the foam. The process would be done by drilling holes into the outside of the house and with a garden sprayer inserting the poly coupler. Mr. Matthew Castriotta of New England Foam and a Mr. Lou Basil from Rapco Foam came and inspected the house and made ar- rangements to have the poly coupler inserted. Donald then told NAUFIM that if this did not work, he would sell them the house for $60,000 to recoup our losses and they could experiment all they wanted to. No change was noticed and in December 1978 Mr. Campbell agreed that the foam should be removed, but that NAUFIM did not have any funds. I contacted Mr. Killeen about Mr. Campbell's decision, and he told me he did not have any funds or insurance to cover the liabili- ty of defective foam. At the time when the original contract was written, Mr. Killeen assured Don that he was completely covered for any mishaps. Mr. Killeen supposedly has hired a lawyer to check on his insurance. The stress is really building up. Don is upset with NAUFIM and the installer. We do not have a home. The girls are unhappy with their living arrangements, and everything seems sour. In January of 1979 I went to Hyannis Cooperative Bank, ex- plained my dilemma, and asked for a loan to remove the foam. I already had a $20,000 mortgage and a car loan with them, and now I was asking for $14,000 to tear down and rebuild my home. In February they decided to lend us the money as the house would never be any good to anybody unless something was done. I also borrowed money from my uncle, my mother, and my chil- dren's college fund. We hired Mr. Alfred Martin, a Cotuit contractor, to begin the re- moval process. The underground part was done from the inside, and the above ground from the outside. When the cavities were PAGENO="0084" 80 open some of the foam was like popcorn, and in some places it had shrunk and there was not any left. After the removal was completed and the house put back togeth- er, NAUFIM hired a deodorizing contractor to mist the house for any traces of formaldehyde. During the summer of 1979 I cleaned and moved my belongings back into the house, but I still became dizzy and had burning eyes and throat. We then used a deodorant called "Gone." It was recommended to us by an undertaker who uses it in his facility to rid traces of formaldehyde. I began to get more and more upset. I believed the money was spent in vain, and the removal did not work. At this point Don and I could not hold a conversation. All we seemed to do was scream at each other. After 21 years, our marriage was really shaky. At this point we decided to move in and try it for a month. We left the girls with my mom. With windows open and the help of Gone, we stayed and after a month moved the girls home. Two years later in November 1979, after our initial exposure to UFFI, we were to become a family with a home once more. Our mental health, our physical health, and our financial situa- tion all has been deeply affected. Five years have now gone by and life is somewhat normal, but the questions always arise: What effect will my exposure to the high levels have on my future health and especially the health of my children? Why do the chemical companies fight as they do? Why spend the money on lawyers and not on helping families? I certainly hope the ban is upheld, and no more is sold. Enough heartache has been caused. I have had a lawyer working with me since 1978, and still have no clue to the manufacturer of the foam installed in my house. In March 1980, I received a letter from Mr. Donald Mackie, com- pliance officer, with the Consumer Product Safety Commission stat- ing he would help me find my manufacturer and to this date, May 1982, have not received any information. Medical records of my family, pictures of the removal, and com- plete removal procedures are available should you need them. I have two letters which I would like to have inserted in the record, one from the CPSC and the other from the NAUFIM. Thank you. Mr. ROSENTHAL. Without objection, so ordered. [The letters referred to follow:] PAGENO="0085" 81 S CONSUMER PRODUCT SAFETY COMMISSION ~ ~ Off I.. 100 S,,,,,,,,., S,,..~, ~ 1607 ~ M~..,,k,,.,,t, 02110 617.223.5576 March 21, 1980 Mr. Donald I. Barth 68 Furlong Way Cotuit, Massachusetts 02638 Dear Mr. Barth: During your testimony at the East Hartford, Connecticut public hearing, you indicated that you had been unable to identify the manufacturer of the urea formaldehyde foam installed in your home (see page 252 of the enclosed testi- mony transcript). If the manufacturer is still unknown at this time, and you have need for this information, we are prepared to assist you in developing this information. Please contact me at 223-5576 as soon as feasible so we may further discuss this matter. Sincerely, ~ Donald A. Mackie Compliance Officer Enclosure - 1 DAM :ncr PAGENO="0086" 82 NATIONAL ASSOCIATiON OF UREA FOAM INSULATION MANUFACTURERS 8025 Dixie Hwy. Florence, Ky. 1410142 April 14, 1979 Mr. Donald Barth 65 Furlong Way Cotuit, Massachusetts Dear Mr. Barth: The National Association of Urea Foam Insulation Manufacturers is greatly concerned about your problem and we will be in the Boston area the week of April 16th to do our best in eliminating your problem. Your full cooperation is needed so that we can attain this goal. Some of the information that we will need includes, (1) what is the best time to catch someone at home, (2) what do you feel the problem is, (3) and do you have any opinions as to what it would take to rectify this problem. If you will answer these questions and return this to me immediately, it will help us in determining on how best to solve your problem. Thank you very much for your cooperation. Sincerely, NAUFIM - ,~;_. ,e/ ~ William Egnb' ( President ~j/ 4'. - - -. -I' 2, WE:dw (1~.~L' ` - 7 - - ~-- -- - - ~-" - - I t-~- ~iy~ . -/~ I ~- -~ ( ~/--~.&. .~ ~`EV~ K~PI Po/~~~' PAGENO="0087" 83 Mr. ROSENTHAL. Thank you very much. Dr. Prisand. Welcome; you may proceed. STATEMENT OF DR. GARY M. PRISAND, UFFI HOMEOWNER, NEW JERSEY Dr. PRISAND. Thank you, Mr. Chairman. My name is Dr. Gary Prisand. I graduated from the New Jersey College of Medicine and Dentistry in June 1974. I have been prac- ticing general dentistry in New Jersey for the past 8 years. In December 1976, my wife, Hannah, and I met with an architect and builder and we started the process of designing a new house. We worked very closely with architect Samuel Abate of Asbury Park, N.J. By April 1977, the plans were completed, and construc- tion began later that month. I would just like to say that we are speaking about a large con- temporary, very modern home and not a mobile home. Williamsburg Estates, Inc., Dominic Martelli, president of Shrewsbury, N.J., was the general contractor. Urea formaldehyde foam insulation was recommended by the builder, the architect, and the electric company. It was installed by Modern Gas Service of Lakewood, N.J. in the summer of 1977. We paid the builder $1,200 in addition to the $1,200 insulation allowance that was called for in our contract. My wife was at the job site daily during installation of the insulation. All of the installers were wearing protective masks but none was offered to my wife, Hannah. She continued to visit the construction site, scrutinizing every aspect on a daily basis. Shortly after the urea formaldehyde foam was installed, Hannah started to develop allergy-like symptoms-mostly nasal congestion with very thick mucus, but also watery eyes and the general feel- ing of malaise. Even though Hannah had no history of allergies, at first we at- tributed the symptoms to hay fever. We moved into the house on October 29, 1977, and Hannah's symptoms immediately became much worse. Hannah went for a complete physical exam to a local internist, Dr. Kahn of Red Bank, N.J. He told us Hannah had sinusitis and started her on antibiotics and antihistamines. Several weeks later as the symptoms had only worsened, Hannah was referred to an ear, nose, and throat specialist, Dr. Stark of Middletown, N.J. Dr. Stark continued treating for sinusitis with several different antibiotics and antihistamines. He saw Hannah on almost a daily basis to suction mucus from her nose. By the end of December, Hannah could not draw any air through her right nostril. Dr. Stark told me that one side looked like sinus- itis, the other side, an allergy. He just did not know. Perhaps there was a nasal polyp. When Hannah began having severe nose bleeds and coughing blood, Dr. Stark referred us to another ear, nose, and throat doctor, Dr. Lenczyk. He was not able to shed any light on the situation. PAGENO="0088" 84 During the next month sinus X-rays and tomograms were taken by Monmouth radiologist with no positive findings. At the end of January, quite by accident, Dr. Stark suctioned out a piece of tissue from Hannah's right nostril. He sent this to Riverview Hospital in Red Bank for pathological examination. The biopsy was read as nasal polyp with hyperplasia, but sam- ples were sent to the Armed Forces Institute of Pathology for an- other opinion. We waited a few weeks for the report to come back from Wash- ington. During this time Hannah's symptoms were worsening so Dr. Stark and Dr. Lenczyk decided she should be admitted to River- view Hospital so they could remove the polyp and look around. We were very uncomfortable with the situation so I decided to find an ear, nose, and throat doctor outside our local area. Friends of ours got us an appointment with Dr. Joseph Goldman who had been the Chief of Otolaryngology at Mount Sinai Hospital in New York City. As we were getting ready to leave for Dr. Goldman's office, the telephone rang. It was Dr. Baldi, the pathologist from Riverview Hospital. He was calling to tell me that he had received a phone call from Dr. Hyams at the Armed Forces Institute of Pathology and that Hannah had cancer. He explained to me that she had an undifferentiated squamous cell carcinoma and must have immediate treatment. I called Dr. Hyams in Washington and he confirmed the diagnosis and the need for treatment. Dr. Goldman did another biopsy in his office and called Dr. Sil- verstone, a radiotherapist. Radiotherapy for cancer of the naso- pharynx was started the next day. Three days later the report from Dr. Goldman's biopsy was read by Dr. Kaneko of Mount Sinai Hospital as an inverted papilloma with hyperplasia and atypia. Mr. ROSENTHAL. What does that mean? Dr. PRISAND. These are precancerous changes. So far we have four or five different pathologists reading the same report-- Mr. ROSENTHAL. At that point you should not have done the radi- ation. Dr. PRISAND. That is correct; the radiation should not have been started. We have several different pathologists not agreeing on a diagno- sis, given similar evidence-this is typical with nasal tumors. This is very typical with these tumors. Dr. Goldman had left for Florida so Dr. Biller, the current Chief of Otolaryngology at Mount Sinai hospital admitted Hannah to Mount Sinai. He did a complete workup, including blood test, CAT scans and biopsy under complete anesthesia. There was still a difference of opinion between the pathologists but it was agreed that in order to save Hannah's life this tumor must be surgically removed. Dr. Goldman and Dr. Biller did a medial maxillectomy and later- al rhynotomy in March 1977. This is a 5-hour surgical procedure PAGENO="0089" 85 done through the face which leaves a scar around the border of the eye and the side and lower border of the nose. The doctors said they completely removed the tumor. Recovery from the surgery was very slow and painful. I personally took a set of slides around to five or six different pathologists. In fact, I flew Dr. Hyams in from Washington. He is the Chief of Otolaryngology at the Armed Forces Institute of Pathology. We sat in a room with about five pathologists. There was Dr. Hyams, Dr. Kaneko, Dr. Goldman, Dr. Biller. We still could not agree. After being released from the hospital, Hannah did not seem to be healing properly at home. She was rushed by ambulance to Riv- erview Hospital with hemorrhaging and during April was admitted twice for several days at a time. The doctors could not understand why Hannah was not healing. When Hannah was hospitalized in April I started reading about nasal tumors. I went to the library at the New Jersey College of Medicine and Dentistry and did computerized searches of the cur- rent periodical literature. I did extensive reading of squamous cell carcinoma and its rela- tionship to papillomas. I literally spent months reading. I read ev- erything that Dr. Hyams wrote on nasal tumors. Names such as Dr. Hyams of the Armed Forces Institute of Pa- thology and Dr. Perzin were routinely cited as references through- out the literature. By June Hannah was out of bed and it was decided -by Dr. Biller, based on the diagnosis by Dr. Hyams and Dr. Perzin that radio- therapy was necessary. Dr. Chang, the chief of radiotherapy at Columbia Presbyterian Hospital in New York confirmed the diagnosis and planned treat- ment. Hannah went to New York for treatment 5 days a week through- out the summer of 1978. By the end of treatment, Hannah could not speak, hear, smell, or taste. She had no saliva and could not swallow. She was still having nosebleeds and was down to 82 pounds. Mr. ROSENTHAL. How old was she? Dr. PRISAND. She was 27 at the time. She is 32 now. Around the beginning of 1978, she began having severe nose- bleeds and that is when the local doctors decided to admit her to Riverview Hospital and that is when I said let us get into New York City and see what was happening. Those nosebleeds were very severe. During the past 4 years Hannah's problems have continued. She is plagued with nasal crusting and bleeding and must irrigate her nose daily. She has no sense of smell, only partial taste, and no saliva. She carries a water bottle at all time and must constantly sip from it in order to eat, swallow, or speak. She has recently regained her hearing but damage to the pitu- itary has interrupted her menstral cycle and left her infertile. Recently I saw the television show "20/20" and listened in `~iorror as I realized that our urea formaldehyde foam insulation PAGENO="0090" 86 may have been the cause not only of the tumor but also of the in- ability to heal and all the other post-operative complications. I went back to the literature from 4 years ago and also started to collect all data available on urea formaldehyde foam. .1 found that Hannah's disease, squamous cell carcinoma of the nasal turbinate area, was exactly what the rats got in the New York University study. I further found that this is an extremely rare tumor that is asso- ciated with the cancer-prone age group. All along for the past 4 or 5 years, the doctors-and I am talking about the chief at Mount Sinai, at Columbia Presbyterian, and New York University-could not understand why she was having this crusting problem, why she was continuing to have nosebleed- ing. They feel that they cured the primary tumor, but they cannot relate to these other problems. They just do not have any idea why she has these other problems. I have a summary of five or six studies that show that this par- ticular tumor occurs basically in the 50-, 60-, and 70- year age group. I would like to submit those for the record. Mr. ROSENTHAL. Without objection, so ordered. [The list referred to follows:] Captain Vincent J. Hyams.-Titie: Papillomas of the Nasal Cavity and Paranasal Sinuses; A Clinicopathological Study of 315 Cases. "19 of 315 cases of inverted papilloma had squamous cell carcinoma associated with it. The age of the patients with associated malignancies is essentially limited to the cancer prone age group." Meyer and Wang.-Title: Carcinoma of the Nasopharynx; Factors Influencing Re- suits of Therapy. "The average age of 122 male patients was 50.3 years, that of 48 females was 50.9 years." Snyder and Perzin.-Title: Papillomatosis of Nasal Cavity and Paranasal Sinuses (Inverted Papilloma Squamous Papilloma) A Clinicopathogic Study. "Papillomatosis is a condition found predominantly in men in the age group 40-70 years of 39 cases eight patients had squamous cell carcinoma associated with papil- lomatosis; age 51-64." Suh.-Title: Inverting Papilloma of the Nose and Paranasal Sinuses. "Inverting papilloma it occurs predominately in males 47 of 57 cases or 82 per- cent; 75 percent between the ages of 40 and 70; 1 of 57 cases below 31 years of age." Bosch-Title: Cancer of the Nasal Cavity. "40 cases of cancer of the nasal cavity . . . more frequently seen in males than females in a ratio of 5 to 3. The youngest patient was 35 the oldest was 88 and the median age was 67 years, only two cases under 40, 75 percent were 60 years of age." Dr. PRISAND. As you can see, these tumors do not occur in 27- year-old females. I hope you realize that we are talking about a new family-a young mother of 27 with a little 2-year-old baby and a house built on dreams and life savings. With the knowledge we have now, after hearing the "20/20" report and the literature we have collected, I must say I am shocked and appalled that it was the cause of the formaldehyde in- dustry, not fate, or an act of God, that caused us this pain and heartache. Formaldehyde levels in our house were measured recently and found to be in excess of the 0.5 parts per million recommended as an uppermost level. PAGENO="0091" 87 Now we are faced with the ongoing problem of the urea formal- dehyde foam. We cannot sell the house and it may cost upward of $40,000 to remove it from the walls. My wife and I only hope to help save others from this anguish we are living through. It is mind boggling to realize that all of this could have been avoided if only for a warning. Thank you. Mr. ROSENTHAL. How have you maintained your sanity? Dr. PRISAND. It is very difficult. We do not know where to turn first. When I speak with the doctors they say they have never heard of it. The report from the Consumer Product Safety Commission says, "Ask your physician." When you ask your physician they say: "I do not know. Show me the literature." I have been going to the literature to show the doctors. I have taken many courses on head and neck cancers. I have cornered chief surgeons. They have never even heard of urea formaldehyde foam. Mr. ROSENTHAL. Where is your wife? Dr. PRISAND. My wife is in Washington today. Mr. ROSENTHAL. How is she? Dr. PRISAND. The primary tumor seems to be under control. As I said, she cannot smell, she cannot taste, she has no saliva. She car- ries a water bottle everywhere. She feels she has memory loss. It could be a personality thing. She is infertile. She has no menstrual cycle. She lives in constant fear of recurrence of the nasal tumor. Nasal tumors tend to recur over a wide area. She is living in a house that is just the realization in her mind- we are still in the house. Mr. ROSENTHAL. Why do you not get out? Dr. PRISAND. What do we do with the house? It is our life sav- ings. I have had many builders in to give me estimates. They will not even come up with estimates because of the problems. They are told that the material has to be removed to somewhere in Pennsyl- vania. The walls have to be washed with sodium bisulphite. They cannot even give me estimates on removing the material. I cannot sell the house. It is a mind-boggling situation. Mr. ROSENTHAL. Thank you. Mrs. Geller. Welcome; you may proceed. STATEMENT OF JEANETTE GELLER, MOBILE HOMEOWNER, LITHIA SPRINGS, GA. Mrs. GELLER. Thank you, Mr. Chairman. You have my prepared statement and I will attempt to tell you of some of the highlights and some of the things that have hap- pened to me. Mr. ROSENTHAL. Without objection, your statement in its entirety will be placed in the record. PAGENO="0092" 88 Mrs. GELLER. My husband and I purchased a new Fleetwood mobile home in 1975 after he retired from Ford Motor Co. Mr. ROSENTHAL. Where do you come from? Mrs. GELLER. I am from Lithia Springs, Ga. We purchased a lot in White County, Ga., after my husband re- tired. We purchased a new Fleetwood mobile home because it was instant housing. The dealer told us that it was well constructed and it met our needs, plus the fact that Fleetwood stood behind it with full service warranty and would fix anything that was wrong with the home. We moved into the home on November 12, 1977. On November 13, 1977, I woke up with laryngitis and headaches. My husband awoke with severe `headaches and what appeared to be a cold. We got plenty of bed rest, drank lots of fluids as it was on the weekend. On November 14 we had not improved. We called Dr. James K. Mitchell, our family physician for many years and told him our symptoms. Dr. Mitchell phoned us a prescription for flu. This did not help. On November 16, Wednesday, I worked 4 hours that day. I had been out of work on Monday and Tuesday so I forced myself to work. As the day wore on, I began to feel better. By noon when I re- turned home I was feeling really good. I was disappointed that Jack had not improved. I really thought the medication had helped. Shortly after I re- turned home I again developed nausea. A short time later I was vomiting. My voice began to fade again. This continued. I was off on Thursday. I stayed in and continued on the medication that Dr. Mitchell had prescribed for the flu. Jack continued on it. On Friday, once again I forced myself back to work. Again I im- proved once I was at work, about 2 hours later. .1 returned home that evening. Shortly after I went into the house I felt nauseated and my voice began to fade. A short time later I was vomiting. Jack had continued with severe headaches, flu-like symptoms, and congested in the chest. Nothing improved very much in the days that followed. On Saturday when I returned and I began to feel sick shortly after I got home, I asked Jack to take a trip and see if we both improved as I had at work. We did. We spent the weekend with my sister and we both im- proved shortly after we left home. We continued to feel good until we returned home late Sunday night. While preparing to go to bed the old symptoms began to return. I began to lose my voice, he had taken a headache. Again, I was nau- seated and vomiting. This continued through the months that followed. On January 23, I awoke from a deep sleep around 1 o'clock in the night. I could not breathe. I felt like someone was choking me or stuffing my throat with rags. PAGENO="0093" 89 I tried to get up and I was unable to stand. I was dizzy; I was nauseated. I tried to wake Jack. I had no voice. I could not call him. I grabbed a blanket from the bed and started crawling for the door. This awoke him and he got up and pulled me to the door and out into the air. A short time later I began to improve and I spent the rest of the night in the car. On the 24th we removed the carpet because the dealer had told us the dye in the carpet was probably our difficulty. So we removed the carpet. We stayed out working through the night and put down tile. On Thursday we finished removing the carpet and putting in tile. This did not help. Again, I awoke choking and I spent the rest of the night in the car. In February 1978, 3 months later, I thought maybe a humidifier would put moisture in the air. We purchased a humidifier. This did not help. Once again I called Dr. Mitchell and went in to see him. He pre- scribed more antihistamines and more flu medicine. He said I had an infection of the ears, nose, and sinus. We continued on that. We did not improve. Jack began to have severe headaches and several nosebleeds. In March a neighbor of ours saw a small article-and she had also been affected in our home and her small son had had severe eyes burning, headaches when they were there for a short time- referring to the "mobile-home syndrome." I immediately called Dr. Mitchell. He said he had never heard of such a problem, but he suggested we buy two air filters, electronic air filters. We did. We put one in the living room and one in our bedroom. This did not help. We continued trying to get the dealer, Mr. Cook at Marietta Mobile Home and Fleetwood Mobile Homes of Georgia, the manu- facturer, to come and inspect our home. They had told us the odor would be gone within a few days. It was not. They would not come out. Finally in March we started contacting HUD for their assistance. We were told to have our home checked by the Georgia State fire marshals. We did this. They checked our home on May 8. The gentleman that inspected the home said that he saw we had troubles yet in his report he referred to no problems whatsoever. Dr. Mitchell referred me to Dr: Tinkelman. Dr. Tickelman is an allergist. He said he had never heard of a problem such as mine before. Dr. Mitchell had called him. He examined me. He sent an aide of his to the medical library to check out the symptom and treatment. He said there was absolute- ly no treatment or nothing with regard to formaldehyde in the medical library at that time and that I had as much information in a small article that was taken in the Family Circle magazine as they found in the medical library. We continued to leave our home. We only returned to take a bath and change clothes. I continued to sleep in the car throughout the winter of 1977 and 1978. PAGENO="0094" 90 In June 1978, we had our home tested. The formaldehyde count was 0.403 parts per million. It was tested by Rossnagel & Asso- ciates. We were advised by them to move if at all possible. Dr. Mitchell also advised us to move. Dr. Tinkelman said if we could not move, we should continue to spend most of our time away from home, which we did. We did not know how to have our air tested. We sought legal aid, trying to get out of the home because we had a mortgage on it. He was told that we would have to have the air tested before he could do anything for us to see if it were formaldehyde in the home. We again contacted HUD for their assistance. We were referred back to Peter Breysse. Dr. Breysse told me that I could probably find a chemist in Atlanta that would test the air in the home. Rossnagel tested the home. On October 11, 1978, Georgia Pacific and Weyerhaeuser road tested the home under their supervision. The count was 0.78 parts per million. This was 11 months after we had first moved into the home. We had no other contact with Fleetwood or anyone until March 21, 1979. We moved out of the home January 1, 1979, because I could no longer spend the nights in the car. On December 6, 1978, Jack had a severe nosebleed. We had to take him to the ear, nose, and throat doctor, Dr. Mitchell. He discovered he had three ruptured blood vessels when we ar- rived at his office. He had to cauterize them. We built a small three-room house and moved into it the first of 1979. I continued to have memory lapses and temperament changes. Jack continued with headaches. The nosebleeds, nausea, and vomiting had improved, but my dis- position had not. I continued to have skin problems and I had to have one growth removed from my scalp and one from my nose. They were nonma- lignant. We had enjoyed our home, but I found that I had to give up work because as a bank teller I had to have good memory and I could no longer tolerate smoke or anyone wearing perfumes. I would get deathly sick or I would lose my voice. I would start sneezing or coughing. I could not wait on customers. We discussed the problem and we sold our home. We are now renting a small apartment in Lithia Springs, Ga. We stopped making payments on the home on the advice of our attorney in August 1979. In November 1979 the finance company filed repossession for the home. They picked the home up in December 1979. At this point the home is in litigation and we have no information of when we will recover any of our investment and our health problems continue. Jack is now on the borderline of glaucoma and on the borderline of a liver and pancreas disorder. I have constant ringing of the ears. 1 still have memory lapses and I am unable to go shopping in stores because I will become totally disoriented. PAGENO="0095" 91 I get turned around. I cannot even find the car once I head back for the outside. I do not want to leave the impression that we blame formalde- hyde for all our illnesses. However, up until November 1975, we were healthy, had lots of energy, and we were enjoying life. At this point we are isolated and cannot enjoy life as we did before. Thank you. [Mrs. Geller's prepared statement follows:] PAGENO="0096" 92 Ladies and Gentlemen: My name is Jeanette Geller P. 0. Box 835 Lithia Springs, Georgia 30057 After Jack (my husband) retired from Ford Motor Company in 1975 we started looking for a place to spend our retiring years. We wanted to leave the big city, Atlanta and the traffic. May, 1977, we located a beautiful lot in White County, Georgia. The property sloped gently down to a crystal clear trout stream. That same day I applied for and got a job at the White County Bank, Cleveland, Georgia, as bank teller. I reported to work June 13, 1977. We located and rented a house until we could check with some local builders and check on some mobile homes. We decided to purchase a mobile home, because it was instant housing. We chose a Fleetwood mobile home that cost us $14,677.50 unfurnished, because we were told by several dealers that this home was considered to be the top of the line. It seemed to be well con- structed and the dealer told us Fleetwood Enterprise, Inc. stood behind their full service warranty. Supposedly if anything was wrong with their homes it got fixed. It is very difficult to describe in a few words the numerous health related problems that Jack and I have experienced after moving into our new mobile home, November 12, 191.7. It is impossible to :name~ the many people we talked with by phone and wrote, who were associated with Fleetwood Enterprise, Inc., PAGENO="0097" 93 Fleetwood Homes of Georgia, Inc. and various federal and state agencies while trying to find a solution for our health related problems and to make our home liveable. You will find a copy of a few of the letters we have received in response to some of our phone calls and correspondence attached. On November 13, 1977, the morning after we moved in, when we woke we thought we had taken a cold or flu. I had a headache and laryngitis. Jack had a headache and was sneezing. We did the usual things we got plenty of bed rest and forced fluids. On Monday, November 14, 1977 we had not improved. Jack called Dr. James K. Mitchell, our physician for many years, and told him our symptoms. Dr. Mitchell phoned us a prescription for the treatment of flu to the local drug store. We started taking the medication that same day. We did not get any relief. On Wednesday, November 16, 1977, four days after moving into the home I forced myself to go to work. I was one of three tellers that worked every Wednesday until noon. Thursday was my day off. When I left the house Wednesday morning November 16, 1977 I was nauseated, vomiting and still could not talk. I was delighted when my voice began to return and I noticed that I was feeling better. By noon I was feeling good and looking forward to going home and finish unpacking. I was disapointed when I got home at lunch and found that Jack had not improved. Jack had remained at home all that morning inside the trailer. 97-153 O-82--7 PAGENO="0098" 94 We had lunch and before I could even clear the table my voice began to fade. I became nauseated and a short time later I was vomiting. I still thought I was suffering from the flu and I rested that afternoon and Thursday. We continued on the medication. That first Wednesday, Jack called Bill Cook at Marietta Mobile Homes, the dealer, and inquired about how long it would take for the odor and our burning eyes and nose to stop. Mr. Cook said, "it should be out by now but I'm sure it will disappear soon. It is the new smell and some of it may be the dye in the carpet." We had inquired about the burning of our eyes and nose, at several mobile home lots, when we were shopping for our home. Each dealer had told us pratically the same thing. The problem was that the mobile home was new, the windows were kept closed and the home was sitting on an asphalt lot. We were told the odor would disappear in three or four days, once the home was set-up on our lot and we started living in it. The first Friday and Saturday I forced myself to go to work even though I was nauseated, vomiting and could not talk when I left home for work. Again I improved during the day when I was away from home. By the time I returned home I would begin to feel sick with in 30 minutes every day. On Saturday, November 19, 1977 seven days later when my symptoms started to return within 30 minutes after I arrived home from work. asked Jack to take a trip for the week-end and see if we both improved. We spent the week-end with my sister. Jack did not feel up to a trip PAGENO="0099" 95 but we finally decided to leave about 3 p.m. that afternoon about 2 hours after I got home. We did not return until late Sunday night. We both started to feel better about and hour after we left home and continued to feel good until we returned home. By the time we had been back home about 30 minutes our old symptoms began to return. This is when we started trying to figure out what was there that would cause our headaches, sneezing and my loss of voice. The odor was the only thing that was noticeable outside of our physical problems. After that first weekend we began leaving home every Wednesday afternoon and returning late Thursday night. We would then leave on Saturday afternoon and return late Sunday night. In January, 1978, two months later, we also started taking a drive every afternoon and not returning until bed time. We did not have a home. We only had a place to take a bath and change clothers. We could not entertain or relax at home. The conditions did not improve in the weeks and months that - followed. In fact, we continued to develop new health problems and the ones we had seemed to become more severe. I continued to leave home sick going to work but improved while I was away from the home. Only now I never seemed to feel good. I was less energetic and I also began to notice that if a customer was smoking or wearing strong cologne near me this would start me sneezing, coughing or I would feel nauseated. PAGENO="0100" 96 We tried all sorts of things to stop the odor and burning of our eyes, nose and throat. We washed the drapes. We washed the walls with both vinegar water and soda water several times. We shampooed the carpet. We sprinkled soda on the carpet and then vacuumed. We would open the windows to let fresh air in even though it was freezing outside. Nothi~ helped. We continued to make telephone calls to the dealer and manufact- urer trying to get someone to come and inspect our home. We thought that we must have an unusual problem with the odor remaining for weeks instead of a few days; since we had been told by the dealer it would soon go away. We were told it had to be the dye in the carpet. January 23, 1978, two months later, I woke about 1 a.m. choking. I felt like someone had their hands around my throat choking me and at the same time stuffing my throat with rags. I was unable to wake Jack. I tried to get up to go outside for fresh air. I could not stand up. The mobile home seemed to be rolling over and over. My voice was gone I could not make a sound. I grabbed a blanket from the foot of the bed and started crawling toward the door. The noise must have awaken Jack. He got up and pulled me to the door and onto the steps. I do not know how long we sat there before he got me into the car. I spent the rest of the night in the car as I was afraid to go back into the home. The same thing happened the next night. We were certain by now that we did not have a cold or flu. It had to be something ir~ the home. Jack's symptoms now inc1udedcon~ stant and severe headaches, skin rashes, frequent nose bleeds, sneezing, PAGENO="0101" 97 dizziness, change of temperament, frequent memory loss and vision problems. My symptoms included frequent headaches, temporary loss of voice, burning and hurting eyes, runny nose, dry and burning throat, nausea, vomiting, blurred vision, change in temperament, loss of energy, depressed, respiratory problems, rash on face and forearms, chest pains, sneezing, coughing, drowsiness, unable to concentrate and forgetting things that I had just read or heard. * I was having trouble at work remembering my customers names or their instructions. I started having trouble balancing. We knew that we had to do something to try and make this home liveable. We could not get the dealer or manufacturer to do any- thing about this condition. On January 25, 1978, two months after we moved into our home. we purchased tile for the entire home. We started that evening ripping the carpet from our bedroom, hall and living room. We worked into the night and we completed putting the tile in this area the next day. However, once again I woke choking and had to spend the night in the car. In February, 1978, three months later, we purchased a humidifier to see if this would make it easier for us to breath. This made the situtation worst. We made several trips to the doctor and each time we got the same medication for cold and flu. They could find no major problem only flu-like symptoms but no temperature. PAGENO="0102" 98 On March 18, 1978, four months after we moved into our home, a neighbor, who had seen us on several occasions when we were very. sick, brought us a small article she saw in the March issure of "Family Circle" magazine telling of the "mobile-home syndrome. She and her small son had also experienced their eyes, nose and throat burning when they were in our home. She thought that If we showed this article to our doctor that he could help us to get well. On Monday, March 20, 1978, two days after receiving the article. Jack took the small article and went to see Mr. Cook at Marietta Mobile Home. When Mr. Cook was asked about the formaldehyde problem his only reply was: "I wish I had never sold you that home." Mr. Cook then turned and walked away. Jack left and called Dr. Mitchell to see if he knew of a treatment for anyone suffering from exposure to formaldehyde. Dr. Mitchell's reply was, "how did formaldehyde get into your home?" He told Jack to get an air cleaner for our home and he referred us to Doctor David G. Tinkelman, an allergy specialist. We purchased two (2) air cleaners. One for the living room and one for our bedroom. They did not help. Dr. Mitchell advised us since the air cleaners had not relieved our symptoms that we should consider making other living arrangements since he knew of no treatment. On April 26, 1978, five months later, I saw Doctor Tinkelman. Jack would not make an appointment, he said, `if Doctor Tinkelman helps you then I will make an appointment." PAGENO="0103" 99 Doctor Tinkelman could not understand how we had been exposed to formaldehyde in our home. He said, "I had never heard of such a problem until James called me about you." He sent one of his aides to the~medical library to research formaldehyde poisoning symptoms and treatment. He said that the small article I had contained as much information as his aide found and copied from the medical library. As far as he knew there was no treatment except to remove ourselves from the home. If we were unable to move then we should continue to spend as much time out of the home as possible. We did not want to just stop making payments on the mobile home and have it reposessed as this would only hurt us. This mobi~le thome was setting on our. land and we did not want to leave :~our property. We could not afford to make a house payment and rent a home. We sought legal advice from Mr. Ray Gary. We thought since this was a health problem, surely there was .some law that would require the dealer or the manufacturer.to.,make the home liveable, replace the home or refund our money. Jack had phoned HUD ~earlier and talked with Mr. Jimmah Hyder to~see if HUD would help us get this problem resolved. Mr. Hyder advised us to have our home inspected by the State Fire Marshal's Office. We had filled out and mailed the Mobile Home Complaint form, April 13, 1978 to the State Fire Marshal's Office and we were waiting for an inspection date. PAGENO="0104" 100 On May 8, 1978, James B. Cook arrived from the State Fire Marshal's Office about 1 p.m.. After entering our hone and walking through the home his statement was, "I can see you people have a big problem." About 1:15 that same day Mr. Robert W. Choudoin, Quality Control Superior for Fleetwood Home of Georgia and a Mr. Smith arrived at our home. We talked about our problems for about two hours. Mr. Robert Choudoin made it very clear, as Fleetwood's representative, that our health problems was of no concern of theirs. He was aware that some people just could not live in a mobile home and maybe we were oneof them. He told us we could either learn to live in the home or sell the home. Mr. Choudoin also wanted to know how we found out that the odor was formaldehyde. A copy of our complaint, a copy of Mr. Cook's report, and a copy of Mr. Choudoin's letter to Mr. Jim Williams, dated July 13, 1978 regarding the inspection, is attached. Please note Mr. Coo~c did not mention a odor or formaldehyde in his report. Note Mr. Choudoin's letter to Mr. Williams does mention the problems with fumes. Jack called Mr. Hyder at MUD to see if he could help us with testing the air for formaldehyde. We were referred to Dr. Peter Breysse at the University of Washington. Dr. Breysse told us if we were close to Atlanta that we could locate an Engineering and Testing Consultant in the yellow pages of the telephone book. He said to be sure the firm we contacted could test for low levels of PAGENO="0105" *101~ formaldehyde gas and that they would furnish us a written report. On June 19, 1978, seven months after we moved into our home we had our home tested by Rossnagel & Associates. The test results was .403 ppm of formaldehyde gas in our home. (copy attached) In July of 1978, Ray Gary filed suit in our behalf against A-Bar-G Mobile Homes , Fleetwood Homes of Georgia, Inc. and Fleetwood Enterprise, Inc.. On October 11, 1978, eleven months later, our home was tested by RADCO. This test was requested and supervised by a representative from Weyerhauser and Georgia Pacific. Fleetwood Homes of Georgia, Inc. sent their repair crew to repair any damage that resulted from this test. Their test results were .78 ppm. (copy attached) This was the last contact that we had with anyone from Fleetwood Homes of Georgia, Inc. until March 21, 1979. We did not hear from Georgia Pacific or Weyerhauser. I could not face another winter sleeping in the car, with freezing temperatures. We planned to move. I resigned my job at the White County Bank to be effective November 15, 1978. Mr. Almond, the Bank President, knew our problems with the mobile home and he understood why I was leaving. However, a few days later Mr. Almond asked if he let us have the money, could I come up with a house that we could live in at the present time and one that we could add to, after we got our problems with the mobile home settled, and would I consider staying with the bank? Sure I wanted to stay at the White County Bank and on our PAGENO="0106" 102 property. On December 6, 1978, Jack had a severe nose bleed. It started about 5:30 A. H. the first time but we got it stopped and I went to work. When I arrived home at noon he had had another attack and had not been able to get it to stop. We called Dr. Mitchell and he told us to come into the office as quickly as we could. When we arrived Dr. Mitchell discovered that three (3) blood vessels had ruptured. He said that it was a good thing that we came in when we did because it would not have stopped on its own. We built a small three (3) room house with a basement and moved into it January 1, 1979 even though it was not completed. (Fourteen months after we had moved into the mobile home.) We started sleeping in the basement as-soon-as it was framed-in and the windows set. On March 21, 1979, 16 months after we moved into the mobile home, Mr. Robert Futch, of Fleetwood Homes of Georgia called and talked with Jack. Fleetwood Homes of Georgia, Inc. wanted to send a repairman up to treat our home for formaldehyde odor, if that was agreeable with us. Jack told Mr. Futch that it was fine with him. We were out of the mobile home and had been since January. Mr. Futch called again that same afternoon. I talked with him. He told me that since we were no longer living in the home that they would not treat the home. We were now making two house payments, one on the mobile home and one on our house. PAGENO="0107" 103 On July 23, 1979, I wrote a letter dismissing Mr. Gary as our attorney. On July 31, 1979, we obtained Mr. Douglas E. Smith, Smith and Aligood, Gainesville, Georgia to represent us. Mr. Smith advised us not to make the August payment on the mobile home and to bring him: the payment book. He would notify First Carolina Finance and give them the details. In November, 1979, First Carolina Finance Company filed suit against us to reclaim the mobile home. Two years after we had moved into the mobile home. They removed the mobile home from our property December 19, 1979. The Judge gave instructions that the mobile home should be stored on a lot in Greenville, South Carolina until the suit was settled. We do not know where the mobile hOme is at this time. We have had no communication with anyone regarding the :.home since that date. The suit has been settled. We really enjoyed our home and worked to complete it. It was truly mice to lie on a bed and sleep all night. Our health was improving. However, we continued to have a memory and concen- tration problem. This has not totally returned. There are times that I know someone has said something and I understand what was said, but I am unable to follow through. I forget almost by the time the person quits talking. I became extremely irritable and am still some what so. This created problems for me at work. I lost conf i- dence in my abilities. PAGENO="0108" 104 Mr. Almond asked me in March, 1980, if I would like to take a leave of absence from work until my health improved and the problem with the mobile hone resolved. I did not feel that I could leave my job since we needed my income for add expenses. I continued to have problems at work and being responsible for other peoples money I knew that I had to either take a leave of absence or resign. I did not think it fair to Mr. Almond to ask for a leave of absence because I could not give him a date when I would be able to return to work. We had been out of the mobile home at this time over one year. W&U.. I ever regain my memory and ability to concentrate? Jack and I discussed our problems and decided that we could sell our home to help releave my concern about our added financial burden. I resigned from the bank April, 1980 and we sold our home September, 1980. Presently we are renting a small apartment in my sister's home, as it is not easy to locate an apartment or hone that does not contain particleboard and carpet. The attorney's for Fleetwood Homes of Georgia, Inc. etal filed an ORDER, October 10, 1980 requesting a gag-order be placed on us and our attorney to keep us from talking with other mobile home owners, news reporters or appearing on T.V. or radio to alert the public of the formaldehyde health related problem in mobile hones. The gag- order was removed when we dropped a class action suit. Since we do not understand the legal system we are not sure what this ORDER was all about. PAGENO="0109" 105 We were very disturbed by the gag-order as we felt that the industry had already destroyed our home and injured our health and * now they had taken our freedom of speech away from us also. What would be next? We were being punished while the industry continued to manufacture and sell homes that was making families sick. Where could we find justice? Our health problems that still persist could mean serious health problems in the future. Jack has been told that he is on the border-line of glaucoma, blood test show him on the border-line of a liver, kidney or pancreas disorder, high blood pressure, anemia, his energy level is very low, ears itch and they ring a lot and feel full of water. His last physical before moving into the mobile home showed none of these problems. My reports have shown high cholesterol and the urinalysis continues to show red blood cells. My ears ring constantly, my eyes continue to hurt. I see what appears to me to be small scratches when I look at something white or if I am in bright lights. I started to notice a few scratchs the last part of 1978 and they have increased. The eye doctor has no explanation. I have not been able to find a cure for the rash that keeps reoccurimg on my face. The redness will clear but can return in a few seconds. The rash seems to remain under the skin. Dr. Rabb, a dermotologist said that I would probably always have this problem from time to time. I have had two (2) small growths removed since living in the mobile home. One from my scalp and one from my nose. My temperament has not PAGENO="0110" 106 returned to normal, I am depressed a great deal of the time. Before moving into the mobile home I was never really depressed. People used to tell me that I had more patience and energy than anyone they knew. That has changed and I do not like the change. There are brief periods that I forget where I am or what I was going to do. I have started to introduce my niece to a friend and I forgot my niece's name. Our law suit was filed November, 1979 in THE SUPERIOR COURT OF FULTON COUNTY. Any questions regarding the suit can be answered by our attorneys. We have tried for the past four (4) years to find out how a toxic chemical like formaldehyde found its way into our home, food, clothing, medicine, toothpaste, *furniture carpet, automobiles and other products that we use daily. Formaldehyde has been reported to be a health harzard from the first report ever made regarding health problems. Ladies and Gentlemen, I do not want to leave you with the impression that we blame formaldehyde for all of our health problems; but with the toxic chemical formaldehyde in 8% of our national products, how do you separate the normal health problems from the formaldehyde problems? We have continued to age at the same rate since November 12, 1977, as we did prior to that date, oneday-at-atime. Never before had our health been affected during any 13 month period as it was during PAGENO="0111" 107 the time we spent in the mobile home. During this 13 month period our health improved when we left home and then only to a limited extent. Even now we continue to suffer from the effects of our exposure to formaldehyde. Formaldehyde victims have been referred to as off-the-wall housewives and hypochondriacs, by some people. If we are, these conditions improve when we leave the home. The National Cancer Institute has shown that housewives have the highest job-related cancer rate of any occupation. I believe that we have a right to be concerned and to insist that formaldehyde be removed from products that we use daily and from the homes our children grow up in and spend most of their time. Our. homes should be as free of chemicals as we can make them. Thank you. PAGENO="0112" 108 DEPARTMENT OF HEALTH AND HUMAN SERVICES PUBLiC HEALTH SERVICE NATIONAL INSTITUTES OF HEALTH April 2, 1901 NATIONAL INSTITUTE OF ENVIRONMENTAL HEALtH SCIENCES Mrs. Jeanette Geller P. 0. Box 315 Clermont, Georgia 30527 Dear Mrs. Geller: In response to your request for information concerning the health effects of formaldehyde fumes, I am sending you a coirolimentary copy of the IRCC biblio- graphy "Health Aspects of Urea-Formaldehyde Compounds". Addison-Wesley Publishing Co., Reading, Ma«=~achusetts has also published a book titled, lJrea-Formald~!i~y~ Resins by B. Meyer (1979), in which you may find useful information.. The Consumer Product Safety Comission (5401 Westbard Avenue, Bethesda, Maryland, 20207) can provide you with information on the occurrence and effects of formaldehyde in consumer products. To my knowledge the only treatment for individuals found to be sensitive to formaldehyde, is abolishment of the source of the fumes. I hope this information is useful to you. Sincerely yours, Tern Damstra, Ph.D. Office of Health Hazard Assessment End osure PAGENO="0113" 109 Center for Auto Safety - 1223 Dupont Click Building Washington D.C. 20036 (202) 659.1126 July 2, 1979 William H. Lear General Counsel Fleetwood Enterprises 3125 Myers Street Riverside, California 92523 Dear Mr. Lear: Jack and Jeanette Geller of Cleveland, Georgia, have con- tacted me in desperation about the serious formaldehyde problem. they have experienced with their Fleetwood home. The home was purchased from A Bar G Mobile Homes, Inc. in Marietta, Georgia in November, 1977. One month after purchase, the Gellers requested the dealer to either refund the purchase price or replace the home with another unit as they could not tolerate the formaldehyde fumes emitting from the home. Jeanette Geller's symptoms have been particularly acute. She has suffered dizziness, vomiting, and respiratory difficulty as a result of the formaldehyde environ- ment. Both Gellers have experienced itching and swollen eyes, skin rashes, and severe headaches. They have since moved out of the mobile home on the advice of Ms. Geller's physicians. They have constructed a temporary dwelling where they are now living. The mobile home sits uninhabitable on their. lot. Fleetwood's own test, conducted by RADCO last September, registered an unusually high level of formaldehyde in the home at .78 ppm. I understand that the National Institute for Occupa- tional Safety and Health is recommending a revised standard of 1.0 ppm. for eight hours of occupational exposure. Certainly the home environment to wliich consumers are continuously exposed should be held to a much lower standard of permissible exposure. Unfortunately as .we both know, MUD has yet to devise such a standard. Considering that Fleetwood offers a "full" warranty and that it is subject to the FTC consent order requiring -it to ex- peditiously repair defects which render a home uninhabitable, it is incumbent upon Fleetwood to remedy this situation. Legal arguments aside, I would think that simply as a demonstration of good will, Fleetwood would be more responsive to a problem effecting the health of its customers. The Gellers have exercised extra- ordinary patience and good faith throughout their ordeal. Although living on a fixed income, they have spent a considerable amount 97-153 O-82--8 PAGENO="0114" 110 of money on efforts to alleviate the excess level of formalde- hyde in their home, including replacing the carpet with tile (at the dealer's suggestion) and installing.a $600 air filter. None of their efforts has reduced the seriousness of the prob- lem. Unable to persuade either the dealer or the manufacturer to refund the purchase price of the hone or to replace it with. another unit, the Gellers filed a lawsuit in Superior Court of Cobb County, Georgia (Civil Action No. 783049) to recover / their damages. The Center is extremely concerned about this problem. We have received a significant number of letters from mobile home owners from across the country complaining of high levels of formaldehyde fumes in their homes. We are urging both HUD and the FTC to do something about. this danger to the health and safety of mobile home consumers. In the meantime, I request your assistance in seeing to it that the Gellers' complaint against Fleetwood is expeditiously settled, so that the Gellers can begin to.put their lives back in order. Should you need any further information about this matter, please do not hesitate to contact me. Sincerely, Katherine A. Meyer Director Mobile Home Task Force cc: Jack and Jeanette Geller PamelaDanner, HUD. . Ar~tihur Levin, FTC Randall ~rite~ll, FTC PAGENO="0115" 111 (/ ~F )~ 1ijj~jjj `g/~Q~ ~ INC 3125 MYERS STREET - P.O. BOX 7638 - RIVERSiDE. CALIFORNIA 92523 TELEPHONE: (714)785-3500 TWX: 910 332 1759 0 July 9, 1979 Ms. Katherine A. Meyer, Director MOBILE HOME TASK FORCE CENTER frr AUTO SAFETY 1223 Dupont Circle Building Washington, D.C. 20036 RE: Jack and Jeanette Geller Dear Ms. Meyer: Your letter of-July 2, 1979 directed to William H. Lear has been referred to~m~ for reply. Mr. Lear is out of town for several days. I am aware of the lawsuit filed by Mr. and Mrs. Geller and because of the pendency of the action, I am somewhat reluctant to discuss the case at length. However, there are several comments I can make concerninç information which is not privileged. The Gellers purchased their mobile home sometime during late October, 1977, and. moved in in November, 1977. From the beginning several problems were noted and Fleetwood Homes of Georgia, Inc., issued four repair orders spanrin~ December 6, 1977 to May 18, 1978. The letters noted Mrs. Geller's dissatis- faction with her home and pointed out several areas which needed attention. On April 8, 1978, Mrs. Geller wrote another letter and for the first time mentioned formaldehyde odor. Mrs. Geller stated that a family member had a long history of allergy problems and the formaldehyde odor was contributing to a very uncomfortable situation. This letter was followed by a series of - letters involving the Gellers, the Georgia State Fire Marshal's ~ffice ar~ Fleetwood Homes of Georgia, Inc. A state official inspected the home on May 8, 1978 and noted six items requiring repairs. The inspector noted he was not affected by any odor or fumes in the home. By July 13, 1978, the items listed by the State were completed and while Mr. Geller refused to indicate his acceptance in writing, he did state verbally that the work was satisfactory. The lawsuit was filed on July 24, 1978. PAGENO="0116" 112 Re: Jack and Jeanette Geller .1 On September 29, 1978, RADCO, through the joint efforts of all parties including wood suppliers Georgia Pacific and Weyerhaeuser, took air samples in the Geller home to determine the formaldehyde levels. In an effort to compromise the lawsuit, we offerred remedial measures designed to help lower the formal~ehyde levels but the offer was rejected by the Geller's. You are correct, of course, in stating that there is no standard for formaldehyde levels in homes. It is my understanding that sensitivity to formaldehyde is an highly personal and individualistic situation and that a low level fQr:one personmay be a high level for another. Given the facts of the Geller case, 1 believe Fleetwood's actions have been responsible. I appreciate the Center's concern and we, too, look forward to getting this matter resolved. Very truly yours, ~ Forrest D. Theobald Assistant General Counsel FDT:hk cc: Mallory Smith, Fleetwood/Douglas Richard Hines, Esq. \ PAGENO="0117" OFFICE OF THE ASSISTANT SECRETARY FOR NEIGHBORHOODS VOLUNTARY ASSOCIATIONS - AND CONSUMER PROTECTION Ray Gary, Esq. Gary~ Kerr aed Norman 511 Bankhead Highway, S.W. Mableton, GeorgIa 30059 Dear Mr. Gary: 113 I an resporx3ing to ymir letter of Septeaber 6, 1978, to Secretary Harris which has been referred to this office for reply. The Departrrent is acutely aware of the problens ycur clients, Mr. aed Mrs. Jack Geller, are having with their ntklile hare which was zrranu- factured by Fleetwood -Hares of Georgia. The information that Mr. aed Mrs. Geller provided in their letters to the Departnent has enhanced cur knovledge of the possible effects of an envirorstent where formaldehyde vapors nay be concentrated. The Departhent recognizes that Mr. arsi Mrs. Geller are particularly / sensitive to formaldehyde vapors arsi are experiencing both physical arxl psychological irritation fran the corx3itions present in their hare We ~ gain nore ha 0 of formaldehyde aitgassing in nobile hares aed rrethods of reducing or eliminating the concentration levels. In this pursuit, the Department has initiated a special st~x1y concerning formaldehyde vapor concentra- tion levels in nobile hares, which is a priority activity of the Office of Nobile Hare Standards. Ycxi rajuested that the Secretary issue a preliminary determination to the manufacturer of Mr. and Mrs. Geller's rtthile hare that there is. either a sericxis defect or irrrninent safety hazard caused by the Ianis- sions of formaldehyde vapor. The definition of sermons defect at section 3282.7 (ff), which ties the defect to a Federal standard, prevents the Departnent fran issuing such a determination. This is because the -. Departrrent cuçrently has no standards governing formaldehyde concen- tration levels in irobile hares. - - DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT WASHINGTON. D. C. 20410 OCT 6 1918 IN REPLY REPER TOI PAGENO="0118" 114 I, I ~fr ~ `J(~7 ~ Section 3282.7(q) of the ;egulations defines ~ as "a hazard that presents an(iirtninent ar~3 unreasonabIè~i ôf~~th or s e inj that or nra r~t relateI to failere~Q_ ly with an app cable F~ieral trobile hare construction or safej~yj~_, At e present tiire, t~~t~Iievesi~iaETE1acks sufficient basis to trake a preliminary determination that the formal- dehyde cxitgassing problen poses an irrrninent safety hazard, as it is definef in the regulations, to Mr. aef Mrs. Geller. Ha~ever, wa shall continue to investigate this problen ard wc~.ild appreciate copies of any rnefical reports or other information which yai obtain to iixlicate health prcblera arxi the linkage of these to the formaldehyde enissions in their hare. In the neantime, ycxi nay wish to consider seeking possible raneiies urxler yair State laws. Yos iixlicata~ that the rerefy which yai are seeking for Mr. aef Mrs. Gefler is a rep~rchase of their hare. Please forward to us copies of any corresporxfenca which yai or the Cellars have had with the menu- facturer concerning a rep.rrchase request. The Departhent appreciates the information that Mr. arxi Mrs. Cellar have already sulznitted. r~' icia M. Worthy Depity Assistant Secretary for Regulatory Functions PAGENO="0119" 115 FEDERAL TRADE COMMISSION WASHINGTON. D. C. 20580 BUREAUOF CONSUMER PROTECTION - -* - lIAR 14 ~79 Mr. and Mrs. Jack W. Geller P.O. ~x 127 Cleveland, Ga. 30528 Re: Fleetwood Ebterprises, Inc. Docket No. C-264l Dear Mr. and Mrs. Gefler: Thank you for your letter of March 2, 1979 concerning problerrs you are having with your Fleetwood irobile hose. The Federal Trade ColrEnission has issued an order against Fleetwood designed to ensure that its hates are 5delivered free of rranufacturing defects, that they are properly setgp, and that all problerra covered by the carpany's warranty are speedily corrected. In order to ensure that these goals are rret, the order requires the cxxrpany to inspect each hare prior to its delivery, reinspect each hone twenty-five to forty-five days after sale, and sand each purchaser a questionnaire inquiring atout prcblexre with the hare ninety days after sale. Your letter indicates that your prcblerra with your stabile hose are caused by an allergic reaction to the formaldehyde used to treat parts of your hare. As you are on doubt aware, there are on established rraxinn]m vapor concentration levels for formaldehyde in stabile hares. Furthernore it appears that onl a snail nuet)er the -~/ ~ allergic syrrptars that you d , - The formaldehyde levels do not, therefore, constitute a defect within the ireaning of the Federal Trade Carrnission' s order. 19~~154r~~. _~. I ass sorry that we can not be of greater assistance to you at this tire. The Departrrent of Reusing and Urban Devëleyzrent and the Orinsurrer Product Safety Conrnission are currently investigating the formaldehyde problem in stabile hares~ I am enclosing a copy of the Conirrission's order against Fleetwood, Please feel free to contact ste if you have any problerre that you believe are covered under the order. V truly 9S~ ~anc~1ph W. Tritel Z. t~ Attorney Division of Cbrrpliance - Ehclosure PAGENO="0120" 116 Return to: State Fire Marshal's O'ffièe 7 Martin Luther King, Jr. Dri~re,.;SW Atlanta, Georgia 30334 (404). 656-2064 MOBILE HONE COMPLAINT Date:_ APrfl 7, .te7R_ Name of Owner: Jack W. & Jeanette Geller Phone (Area Code) :.4na_pac_47~ Address: ~ ,- ~. l'7 Cleveland, . Whii-a ~--~`-gla ._-,p~cp~____ Street City County State /~ip Name of Manufacturer: ~ wood - . 0993 CEO - 022242 bcrial Number: Label or Decal Number:___________________ Name of De~ler_ A BAR C Mobile Homes, Inc. Address :850 Cobb Parkway, Nor~~flarietta, Cobb , Georeia .?QQ62_ Street City County State Zip Mobile home was set up by A-Bar-C Mobile Homes (Fred Ruapert) Date Purchased October 27 1977 New ~~~w..j1sed Date of Manufacturer:_ Novernb~j, 1977 - Please itemize one by ore the d'~~ c r' `~m ~n voOr moaile home belo~z Double floor ordered but not installe~j~ndows leak air excessively~iommq~fJiLLrQeL.. * V. bath loose-floor not level under qe.,..jqQE.59fe_weakazid shakeu~LQmad~DUJ.Qns of water traped in insulations under the dinning room floor, Refrigerator door does not close properly, The fumes from the chemicals bos been more. than we can take. We haj~p_ both been ill ever since we moved into this hàme, There is loose screws,. staples. p~p~ug ~np out andy z-icyp other small items~ .* geg for the past week 3~. (Jeanette) bave~çz1..bevinJPa.i2s in the top part of rmj~chest Sincerely, . -. . . - .. . ~ (~-/~7( ~ - . . ~-.r/~.- (~(~12 *~f~ ~ * Jack W. Geller , Jeanette mailer .` PAGENO="0121" 117, STATE OF GEORGIA STATE FIRE MARSHAL'S OFFICE A DIVISION OF THE SAFETY FIRE COMMISSIONER's OFFICE MOBILE HOME CONSUMER COMPLAINT FOLLOW-UP Date of Follow-up £~`-`7~' ,~ vner of Unit ~7~c~' k). ~nJ ~ie1~ &-eJJ~r Pho~e/~4&Wb3~ ~ 3iling Address~i?O. ~Ox /27 City PLPL/e177m./ Zip CodeSOS2g cation of Homei~Y /~.9 ¶!J~ h,,i~ n, ~ ),`t7~fl ~ story of Mobile Home: - odel Name ~6-rA)doo ~j~~2-l' Serial Nurnber~gg3'~' te of Mfg. fl-I- 77 Georgia Decel Number~O O22g'1~. me of Manufacturer. zfress P0 ~r 27~2 Cliy~2u~L~s Zip Code3/S3~ me of Dealer~j1 i3~u? & ~ - dress ` ~`SO Cobb CltyJfhI?/~ft~f Zip Cod&3OO62~ te Unit Purchased /O.-~7- 77 . rson (s) accompsnyln; Spsciallst:_________________________________________________________ vlolatiois of the Georgia Mobile Home Act are noted as follows: 1- ~ ~ ~ ~ - g ?tOI~I ~7fr-ei~nJ `7~c,~pr ~ IA)i#~ibo t-U - . ~ C ~ 77Z7~ te)- 2A,-eo~ jajvs pp~i A Iv C1-OSI~ /4pJf~j~/~(/,'fl~J 574~rIu7~ç, (k)i/Jbp~.J5 5JIOLILID ehe~j~,, igy vrc,n~i~ i~o iii~s~~ Pi~'nPer ~!=1kic rvrnent - 2nd /i~- - . , -. i~Fc/?E)7CE.' ~n. ~3p3 (1:~) ~?. (?c~t~~iaI~ jt !~`pñ~ b,~rw,'co~iit 1oos~ g~ f/ocr. ?)~J7u~thi~r Ji~5 ~&n?~tt~r/ ~reL~'niisi,V let' k?~PJi (i'CJhiYfloIP~, `~ qrl Jii~ ç a~ci-~d 7~ reF,zLLtfft7ptyep~Iy o,t r,vp~tr,~ u~ô7(~J~) ~re t4e~k ~`flci ~451k~y ~cc~rç/jnq7tô ~fl2r ~ ~jy (Use back of page for a'ddttional infor~atiort) ,,. Fire Safety ~ -, --~-: ~: ` PAGENO="0122" 118 ~ noted ,~t -f1ovr ~t ~ 7~4nu1~'c1iire~ h~5 ~reecJ 1~ &~ oi~ts wider ~ ~`re~' c~ retu~~ +rip. `,~ 112/?. (~6Lt~/~. Sz4TES ~ Of W~ Tf P (s~ ~) LJ(15 1'L,,?I 7h-~7pp~J wilr 1/u.~ hoth'm ,~o~rrd ~n- /v~s Li fl;T. ~rni4c tarry- ~ ~ ~ ~ ~ bY/CI~ o7'~ 7~1t~ /e.~'k~, v~;r 1k. f,~v/~' ~itI ~`7~k Lk bofto,~n, )~o~'rc/ ~ y.jturtt, ~tri~p. ~`O. .5 7/'riqer~th5r door d'oes.. n~f C/0se proper(y ?92~nitf~c turer ~ ~r~c/~ 7~ repiir ~/O~ r ~- rr/urn~ ~ ~ ~L)i7~-h~ /,t, LIOiN~- rOOr~~ flo~7Pd ~ 1Loc~se-. Do~ )1O~ ~ Ii~. 5ecureI J~YOJ~-eVILy 1~pikIi7~~ LAJ/1!.~~ C/WIT1. 7Z~2 1~7'iirPd~ 4~s ~ ~reecJ * j'cp~iir (5~curç). tl/r&'/ tnt ~4r~<- ~-ip~ ~ (it) PAGENO="0123" `E4 c~::ô~;I /c25 66243 REQUEST FOR REPAIRS LANT.....Ddp ______________ RODUCT~~,Q~~j. IEALER~74&;~,77~ ~ DDRESSJ~/ ~ 4A,r~,Vt~'~k ~7Kf~F" - EPORTED BY: Dealer ( ) Owner Date_______________________________________ AUTHORIZATION# . ESCRIPTION OF REPAIR ~t~$X fjJ~q~()o4 ~ ~5L1 ,~i z'eiç ~j~4v~j Laze `~ ~4L,, ,~ i~ee.~' ~/~4'pi'~. ~ ~e L4'ck /1,- ~ s~i5';~~j; LØ'I-I. ~ ~r~'Lo-$~; p~%'~. ~ ~ ~ ~ ~ ~ ~ I~f~J/J.e /L5~4'k~ Z,'ak ~`isJg'J ~~s' ~ Ltcc~ ~ ~ Authorized By: 3~~e' ~`~rZ9 Sales Manager A . B. D XPLANATION OF REPAiRS MADE :. . . MATERIAL~ .` . SUPPLIES LABOR. . OTHER EXPENSES 502-1 514 . 505 -. s4a~Lfa94~.-d-..je,p.z~.~ : ~I4 ~dk~1L - . . steWorkScheduled: 4 /q7I~ ste Work ~ >~ ork Accepted as Satisfactory 119 DATE___________ OWNER~~LA. (;:f~~ ~ PARK~.~&,_~ Ii 7~ ADDRESS A /.4L Jo.cZf PHONE~l~-~ 7MW'. DA1~ PURCHASEDJJ-/~- 7] UNITSERIAL# ~7Y/2t4s~Z5 - Prod. Manager Purch. ManagerS Plant Manager - A __________ Sub-Total __________________________ C ________________________ D _______________________ Total Amount Charged Back to Vendor WIllIE - P~odocdon Yegom. Pwthwina Pink. S.tes PRINTED IN U.S.A. PAGENO="0124" 120 DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT WASHINGTON. D. C. 20410 AUG 23 97~ NT 701/841 Mr. and Mrs. Jack Geller P. 0. Box 127 Cleveland, Georgia 30528 Dear Mr. and Mrs. Geller: This is in response to your two recent letters containing several questions and additional information about your symptoms of illness which you believe are related to the formaldehyde vapors in your mobile home. We appreciate the additional documentation you have given us on the possible effect of formaldehyde concentrations in mobile homes on consumers, and your reference to the risks that may be incurred in industry. As you are d¼eare from your copy"of our letter dated June 22, 1978, to Mr. John Gore, State Fire.Marshal, the Department of Housing and Urban Development will be performing aspecial survey in 1978 to gather and collect data on the incidence and severity of formaldehyde concentra- tions in mobile homes. Based on the results of that survey and on -information provided to us by consumers, the Department will determine whether or not to establish standards or requirements for urea-formaldehyde based components used in mobile homes. We were informed by Mr. Jim Williams of the State Fire Marshal's office that he responded to your request for a copy of Mr. Cook's May 8th inspection of your unit by mailing the inspection report to you in mid-June. Fleetwood Homes of Georgia, Inc., reported that on June 14, 1978, the repair which they.agreed on.May 8th to perform on your home was completed to your satisfaction. You acknowledged this by a verbal statement, though not by your signature on the worksheet. Your additional complaint about the level of formaldehyde vapors was not resolved, but as you are. aware, the Federal Standards which the Department enforces do not currently address the issue of formaldehyde vapors. PAGENO="0125" 121 You requested advice on how to get the dealer or factory to buy back your home. The Mobile Homes Procedural and Enforcement Regulations, Section 3282.13 deals with replacement or repurchase of a mobile home from a purchaser. I am enclosing a copy of these Regulations. Since the Federal Standards which the Department enforces through these Regulations do not currently deal with the issue of formaldehyde vapors, it appears that no action can be taken under this section of the Regulation8. If you decide to consider other alternatives, you may wish to consult an attorney for possible remedies under State law. If you do consider selling your unit, we want to point out that not all buyers of mobile homes are as sensitive to formaldehyde vapors as you both appear to be, and that such vapors usually dissipate over time. Sincerely, Tobias A. Gottesman Chief, Investigation and Data Collection Branch Mobile Home Standards Division Enclosure PAGENO="0126" 122 * ~tJ~._J UU * ll11~ I DEPARTMENTOF HOUSINGANDURBAN DEVELOPMENT 0,~ WASHINGTON, D. C. 20410 OFFICE OF THE ASSISTANT SECRETARY FOR NEIGHBORHOODS, VOLUNTARY ASSOCIATIONS AND CONSUMER PROTECTION IN REPLY REFER TO: Mr. John Robert Gore, Jr. State Fire Marshal Office of the Comptroller General 7 Martin Luther King, Jr., .Dtive, S .W. Atlanta, Georgia 30334 Dear Mr. Gore: * This letter forwards additional information which we have received from Mr. and Mrs. Jack Cellar of Cleveland, Georgia. Their letter mentions Mrs. Geller's allergic. reaction to the formaldehyde vapors in their mobile'}some. It also states that some of their complaints may have been caused by damage to the home while in transit to the site. As you are aware, the Federal standards do not currently address the issue of formaldehyde vapors. In order to develop the data and information necessary to make knowledgeable decisions with respect to this issue, the Department will perform in 1978 a special survey to gather and collate data on the incidence and severity of formaldehyde concentrations in mobile homes. Based on the results of that survey, the Department will determine whether or not it should establish standards or requirements for urea-formaldehyde based components used in mobile hones. We will also consider information provided to us by consumers. If you have not already done so, please investigate the possibility that the dealer knowingly sold a unit which did not comply with the standards. Sincerely, Russell H. Dawson / Director Mobile Home Standards Division cc: Mr. and Mrs. Jack Geller PAGENO="0127" 123 GEORGIA ~&!~J4UFACTURED HOUSING ASSOCIATION Suite 110 * Emerson Center * 2810 New Spring Road Atlanta, Georgia 30339 * Phone: (404) 432-4496 Mr. Jim Williams Off ice of State ~ Fire Marshal ,, Room455 `~ 178 J 7 M. L. King, Jr. Drive ST~ - Atlanta, Georgia 30334 -~`~ Dear Jim: I enjoyed seeing you again the other day and sincerely hope that wéwill be able to resolve the problem that HUD seems to think ~e hav~ con~~ning consumer complaints. As pe~ our discussion, I am enclosing two reports issued by our Washington office concerning formaldehyde. I am sorry to say I was unable'to locate the article containing suggestions as to how to possibly rid a mobile home of the smell of formaldehyde. I know from my own experience there have been many remedies suggested in the past, i.e. ~ the home to absorb the. bdor; washing the wails eown with yinegar and. ~ letting them air and dry ror~24 ~xi~irs and then repeating the procedure; and others which I am unable to recall. Needless to say, there is no q~aranteeastothe.res.u1ts.. of any of these methods~ hp~v~r, it would not hurt to try them. As you will note in one of the articles enclosed, it states that, "low levels of formaldehyde~emissions can cause allergic reactions to a small percentage of susceptible pe~sons. Int~~...~e~perienceha:s shown, even this low level of emission vanishes, thus in practically every case and for ~h~tically every person, the problem disappears in time as the formaldehyde works its way into the atmosphere." Jim, I sincerely hope that the enclosed information is of some help to you, but please do not hesitate to contact me if I can provide you further assistance in this matter. Best person~l regards, Charlotte Gattis Executive Director CAG/lbj June 16, 1978 Enclosures PAGENO="0128" 124 ~çED S14~ ( ~ ~ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ` WASHINGTON,D.C.20460 4L PRO~ A PR 5 1982 PESTICIDES AND TOXIC SUBSTANCES Ms.' Jeanette Gelier Post Office Box 835 Lithia Springs, GA 30051 Dear Ms. Geller: President Reagan's Director of Agency Liaison for the White House has *asked me to respond to your letter of January: 6, 1982, in which `you expressed serious concern about the health effects of formaldehyde found in mobile homes. I would like first to express my appreciation for your patience `in waiting for a response `from the Government to acknowledge your. dilemma and provide assistance to you. The Environmental Protection Agency (EPA) `has been .studying formaldehyde for Some time now and is `continuing to evaluate whether certain' uses of formaldehyde pose significant health `risks. However,' ;jusction for the particular application of formaldehyde: .you `are concerned about lies with .the Department `of Housing and Urban Development (BUD). HUD is studying the `outgassing of formaldehyde from its use in particle board, plywood and panelling in mobile homes such `as yours.' While no regulations were .in place at .the time your mobile home was built, BUD did publish an Advance Notice of `Proposed Rulemaking (ANPR) on August 8, 1981, to determine what standards `are needed .to regulate the chemical .in' manufactured homes.' This notice is enclosed for your information. You may also want .to contact `Mr.' Maynard Curry at~HUD (2.02-755-6584): for furthe'r information. We have for- warded a copy of your letter. to him at HUD. As far as receiving compensation or' means of purchasing a new home, you need to deal directly with the manufacturer of your home. Because no federal regulations were `in place at .the time your. home wa's built, the Government `cannot `assist you except to provide you with what we hope `are useful sources of information. PAGENO="0129" 125 You may want to contact the Consumer Product Safety Commission (CPsc). at their toll-free consumer information number -- (800)638-8326. CPSC is actively investigating how to assist homeowners affected by urea formaldehyde foam insulation. Some methods have been proposed for reducing formaldehyde levels in existing homes. Also available for assistance and advice is a private,~ non-profit organ:ization called, "Save Us From Formaldehyde Environment Repercussion" (SUFFER).. Their number is (416)294-3531. SUFFER provides support and an information exchange for. citizens whO have experienced serious formaldehyde problems. I sincerely hope your problems with your mobile home will soon be alleviated. Please be assured the Federal Government is investigating the adverse health effects associated with formaldehyde and the best means of avoiding health risks in the use of thIs chemical. Sincerely yours, 7.. John A.. Todhunter, Ph.D. Assistant Administrator for Pesticides and Toxic Substances 97-153 O-82----9 PAGENO="0130" 126 ~I I..aIIt'J Alleigy Lilitic, PA. South J'ulton Allergy Clinic Cobb County Allergy (lint. ~6~7 VERNON WOODS DRIVE - SUITE A'30 2719 FELTON DRIVE 2480 ~VINDY HILL ROAD - SUITE 201 ATLAN1 A, GEORGIA 30328 EAST POINT, GEORGIA 30344 MARIETTA, GEORGIA 30067 PHONE: 2524207 PHONE: 7684273 PHONE. 434'I071 GERALD E. VANDERPOOL, M.D. - M. SCOTT CARROLL, M.D. - DAVID G. TINKELMAN, M.D. - DENNIS L. SPANGLER. M.D. PR..4 ~77C~ LIMITED TOALLERGICDISEASES May 2,1978 TO WHOM IT MAY coNcERN: RE: ~eanette Geller #51710-2 ~`eanette Geller, a fifty year old female presented to my office on April the 26th 1978 with the following history. In November of 1977 following movinq into a new trailer she developed an upper respiratory tract ailment which persisted and required antihistimine antibiotic therapy. The symptoms were mainly~~f her upper airn'ay and included laryngitis. There was no lower respir- atory difficulty Over the next month she had progressive symptoms including dizziness and vomiting and also had symptoms included respiratory difficulty mainly in the evening hours. Her symptoms were pradominatel~i, while she was at home in the trailer. She did quite well on leaving for work in the morning and the symptoms would recur approximately within one to two hours after re- turning home in the evening. When the windows were open again her symptoms seemed to be some what less but present. The patient did much better when oU# of her trailer for any prolonged period of time. The patient in addition has had an allergic evaluation in 1968 by, Dr. carl Jones, for allergic nasal symptoms which were of minor nature and she has been on oral medications over the last year without any difficulty for this therapy. There is no other history of medical problems. Physical examination today was oseentially within normal limits. There wa~ nc evidence of any respiratory difficulty. Pulmonary function testing was performed and these likewise demonstrated normal pulmonary function in both the large and small airways. Mrs. Geller's history is suggestive of "mobile-home" syndrome. This was described by physicians at the University of Washington in Seattle and is presented in Modern Medicine volume 45 number 16, September 30,1977, page 23. In essence there are certain individuals who are very sensitive to air borne formaldehyde. The particle board, ply wood and insulation in mobile homes are treated with formal- dehyde. PAGENO="0131" 127 iR~:~eanette Geller I have suggested to Mrs. Geller while there is no possible desensitization avail- able at this time, that her best therapy would be to avoid the inciting agent. This would require removal from the formaldehyde environment as best as she is able to do so. At this time I have given Mrs. Geller no medication to be taken on a chronic basis and have suggested that she call me if any further complications arise. If you have any questions, please do not hesitate to contact me. Sincerely yours, ~Jç~LQ/~ ,17ix~r David G. Tin elman,M.D. DGT:cw PAGENO="0132" 128 - ~... sy~:drw~e `(~ ~ ~7 -) __ ~ii~%IViiil~i~ AN UNUSUAL SET of symptoms- ~ iii itation of eyes, nose and throat, ~ labored breathing and nausea-has .~ been noted over the past six years in ~ rnohile.home dwellers in the Seattle area by physicians at the University ~ of Washington, Seattle. The. symp~ ~ toms, mysterious at first, have now been traced to airborne formaldehyde- ~ ___ ______ 8 F1~M]tY CIRCLE 3/27/78 comrng from parucle board, ply~ wood, plywood finishes and. urea formaldehyde ills ulation. In some mobile homes tested, the formaIde~ hyde level in the air has exceeded one part per million, the Government- established permissible exposure. For people who happen to be sensitive to formaldehyde, however, the phy. sicians report, theremay he no safe * k~'d Because the formaldehyde dis- ~pcites over a period of years, the symptoms are precipitated only in newer mobile homes. Modern Medidne: Vol. 45, No. 16, page 23 PAGENO="0133" 129 ~ ~ Mr. Doug Betts October11, 1978 Fleetwood Enterprises Page -2- A written record of the test was established by means of a strip chart recorder and is on file with RADCO. Respectfully submitted, RADC0 1~U~hi41 Patrick M. Morrissey Technician PMM:jjb Enclosures PAGENO="0134" 130 RESOURCES fl ~ ~ APPLICATIONS. fl ~i LU CONTROLS. INC. ________ 16415 AVALON BLVD. ~ f~YJ~jj'.~' CARSON. CA 90749 (213) 532.3842 October Ii, 1978 Fleetwood Enterprises, Inc., 3125 Myers Street L.; ~ ~ Riverside, CA 92523 . . . Attn: Doug Betts Re: Formaldehyde Test No. 78~16 Gentlemen: Attached is. the test data and respective floor plan for the above referenced test. This test was conducted to determine what level(s) of free formaldehyde were present in the referenced home. The equipment used to perform the test was a CIA 555 Gas Monitor. Pertinent information for this test is as follows: Test date: September 29, 1978 Name of hor~e owner: Mr. Jack W. Geller Maximum formaldehyde level found: .78 PPM in hpme. (see ~est report and floor plan for value(s) at specific locations). Observations: One representative from Weyerhauser and one representative from Georgia Pacific were present during. testing. .. All windows and doors were closed during testing. There was no ventilation in the house during testing. The home temperature was that which is considered to be in the comfort zone. ~. . . PAGENO="0135" 131 i;:~ IJ ~i i ~ FOItMALDCIIYDE DAT~\ SHEET s9/29/78 . * 11 :00 A.M.XXXXX - of Owner Nr. Jack W. Geller (lone Serial ~O.G~yLIA846p5~fl993 s Location P.O. Box 127. ClevelandL.cA 3O52~ * Temperature (out.) 700 . Relativo iiu~idity (out.) ___________ (in.) 78 . (in.) ____________ s of Calibration: Loaf D Lia~id Standard a Dial Setting: 4.76 Span Dial Setting:_~~__ a: 0 - 10.0 ppal, 0 - 2.5 ppmD', 0 - 1.0 ppr~ C - 0.5 ppm~ sral Observation (windows, doors, furnace, air conditioning, etc.): Windows Closed ______ _D.anrs_C1a~"~ _~!~_@..jf0 No A/(~ S1i~ht wind - `~`"~" -- ` - ~ -~ ~-~--- ~ WIpL ~ ~ location ~ attached floor. plan): #1 ;2 #3 #4 .#5 _2~ia. ,~zi_. _~iz_ - 8" 48" * 8". #6 `#7 #8 ~78-16-A - Technician(s) _~atrick Morriasey 62~~ 657, 0 1ev~l at % Span: PPM: 5~LEV: PAGENO="0136" B A ~3 rc',\ 97453 165 ;~a0.. Arlington, Tx.. Goshcri Fin!. 132 c3. r -z *1 IL. H * L o5~ tI. £Jj~j1j\ `a'- a PAGENO="0137" 133 I INTRODUCTION Mr. Jack Geller of Cleveland, Georgia, requested ROSSNAGEL & ASSOCIATES to conduct an air contanination test at his mobile hone in Cleveland. This test consisted of Personal Sampler tests using midget impingers for the purpose of quantizing the airborne forrrialde-. hyde concentration. Lawrence P.E. Otwell, Environmental Scientist, originally discussed these tests with Mr. Jack Geller on June16, 1978. ROSS- NAGEL & ASSOCIATES subnitted Proposal #78-~U~8, dated June 16, l978,~ for these tests. The tests were scheduled for and conducted on June 19, 1978, at a central location in the dining area of the mobile home. A floor plan of the test area is shown on Page 5. In Section II are the RESULTS, CONCLUSIONS & RECOMMENDATIONS. Section III contains a complete DESCRIPTION OF TEST. Section IV includes all the CALCULATIONS, and Section V contains all the DATA SHEETS, including an Events Log. ROSSNAGEL & ASSOCIATES wishes to thank Mr. Jack Geller who willingly assisted whenever requested. !9~: This report pertains only to the sample or source tested. Information contained herein is not to be reproduced outside the Buyer's company, in whole or in part, without the prior written approval of ROSSNAGEL & ASSOCIATES, or the Buyer. 3 PAGENO="0138" 134 II RESULTS, CONCLUSIONS & RECONI4ENDATIONS RESULTS A summary of the testing and results is shown on Table I below: TEST RESULTS DATA TABLEI Note: - 1. Refer to Floorplan on preceding page. 5 PAGENO="0139" 135 CONCLUSIONS Presence of airborne formaldehyde in the concentration found represents a significant contamination of the room air. Although the level found was below the 3.0 ppm. O.S.H.A. standaad, it should be realized that this is based on an 8-hour-per-day exposure time rather than the extended exposure of the dwelling place. The most common culprit in this sort of exposure is the curing process of forrnadehyde bearing resins used in textile, plastic, and wood product finishing. The abundance of these materials in the modern mobile home can lead tohigh formaldehyde concentrations in the room air, especially when windows and doors must be kept closed for comfort reasons. This was the case during and prior to our test period. 6 PAGENO="0140" 136 Mr. ROSENTHAL. Thank YOU. Mr. and Mrs. Lovejoy. Welcome; you may proceed. STATEMENT OF JOHN AND CATHY LOVEJOY, MOBILE HOME- OWNERS, CROSS LANES, W. VA., ACCOMPANIED BY IAN LOVE- JOY Mrs. Lovi~joy. Thank you, Mr. Chairman. I am Cathy Lovejoy and this is my husband, John, and our son, Ian. I have a prepared statement which I would ask be placed in the record. Mr. ROSENTHAL. Without objection, so ordered. Mrs. LOVEJOY. This testimony is in~ regard to a 1978 Festival mobile home that John purchased in 1977 by Festival Homes of Ohio, Inc., a subsidiary of Fleetwood Enterprises, Inc. The first years the home was occupied it was solely occupied by John and his daughter, Tracy, whom at the time the home was purchased was 1 year old. After this period we were married and I have a son that is 3 and we moved into the mobile home. Soon after we found that Ian was on his way. John found that in the first year of his occupancy of the mobile home he had headaches, nausea, nasal congestion, recurrent vomit- ing, and they were severe enough to cause him to miss an abnor- mal amount of work. After experiencing this for a prolonged period of time, his con- cern lead him to consult a physician. The physician's diagnosis was sinusitus and he treated him for the same with no signs of im- provement. The record shows that before that time there were no signs of sinusitus. He did have bronchial trouble when he was a child. During the same 3-year period his daughter, Tracy, was experi- encing severe chest colds, coughing, ear infections, sore throats. Numerous visits to the doctor were to no avail and it led to her having her tonsils removed which still did not eliminate the prob- lem. When my son and I moved into the mobile home, we started having the same symptoms which lead to our also seeking medical attention. Prior to our moving in there were no signs of any of the afore- mentioned problems. It was recommended that my son's tonsils would also be re- moved. But the circumstances at the time prevented us from doing so and to this day he still has them. We never had it done. After we were married, it was learned that I was expecting a child and after experiencing no complications with my first preg- nancy, we expected this to be a normal one also. However, I was in the hospital five different times for emergency treatment, the major problem being premature labor from Novem- ber 1981 to January 1982. PAGENO="0141" 137 They had me on medication that caused severe nervous side- effects. Without the medication the child probably would have come early. I had to take it for 3 months. If the child had been allowed to come earlier, then he would have suffered very low birth rate as his weight `at term was only 6 pounds. The last trimester of the pregnacy is when the baby gains the most weight. This was during the last trimester. If he had come early, we do not know what would have happened. After we brought Ian home, he started showing signs of the same problems as the rest of the family-runny nose, constant sleeping, and breathing difficulties. We started hearing about formaldehyde poisoning through the media and our friends kept telling us that, as sick as our family was, we should have our home checked. When Ian came home and started showing the signs, John and I started getting sicker. It was in January. The home was tight. We stayed in the home because the baby was new. We kept getting sicker and sicker. I started checking into it through the State of West Virginia. They referred us-at that time they did not have the equipment to come in and test our home. We called a chemist in Pikeville, Ky., that was able to send us a test that we ourselves could do in the home. Before the test got there we called our doctor and asked if we should remove the child and the other children from the home until the test results were returned to us. They advised us to do so, to get the child out of the home. We took Ian out of the home and in 2 days after I had been fight- ing his problem, his nasal congestion and such for a month, in 2 days he was well. The other children showed immediate signs of improvement also. After we ran the test ourselves we found a level of 0.12 parts per million and 0.26 parts per million. Upon moving from the mobile home, our whole family's improve- ments were dramatic. Through legal counsel we were advised to have the chemist, Dr. Jordan, to come to our home and check the levels himself. Upon doing so he found the levels to be extremely high. Please bear in mind this trailer is 4½ years old. There were 0.54 parts per million in the living room; 0.42 parts per million in the master bedroom; 0.38 parts per million in the children's bedroom; and 0.05 parts per million outside. To date, the emotional and financial stress have been over- whelming. We are still trying to maintain the trailer payment, the lot that the trailer is occupying, plus renting a home that we can comfortably live in. The financial burden is enormous. We have spent over $3,000 in the past year alone in medical bills. This is not even including our moving costs. The emotional problems, with the financial burden-I think the above describe the emotional problems. It is hard to maintain three children, a wife, and two homes at the same time. PAGENO="0142" 138 We have been advised by the bank that after this month they will repossess our mobile home. If this is done-they also advised us they were going to try to resell it. The difference would be our problem. I asked the people at the bank how they could sell a mobile home-- Mr. ROSENTHAL. To whom do they think they are going to sell it? Mrs. LOVEJOY. That is what I am getting ready to tell you. Mr. ROSENTHAL. I have a couple of people I would like to recom- mend. [Laughter.] Mrs. LovEjoy. I asked him how he could do that, knowing that the mobile home is a health hazard. He says the reason they feel they can do that is because we are having such a hard time finding legal counsel that whoever would get the mobile home after us would also have a hard time getting legal counsel. At the present time John has invested $11,000 in the mobile home. If the bank repossesses it, we will not have anything after 5 years of work. This is where we are. We are renting a home. They are getting ready to take ahome that we thought someday would be ours. Thank you. Mr. ROSENTHAL. This committee made arrangements to bring your mobile home outside. That home is 4 or 5 years old? Mrs. LovEJoy. Yes, sir; 4½years. Mr. ROSENTHAL. That is the home between the Longworth and Rayburn Buildings. We had it tested last night by an outfit called Biospherics of Rockville, Md., an environmental consulting and industrial hygiene firm. They tested the formaldehyde levels in your home last night and they were as follows: .38 parts per million in the kitchen; 0.48 parts per million in the living room; and 0.55 parts per million in the large bedroom. Mrs. LoVEJ0Y. It is 4½ years old. Can you imagine what it would have been when it was new? Mr. ROSENTHAL. That is not much of an improvement. The test was No. 125, established by the National Institute of Oc- cupational Safety and Health. Mrs. LovEJ0Y. My husband and our 5-year-old daughter, the two that were exposed to the formaldehyde for the longest period of time still have trouble. I am just learning myself how to deal with this through SUFFER. There are so many things that can affect us that we do not even know about. Our physicians do not know anything about it. The legal counsel in our State does not know anything about it. There are very few. I cannot find anybody who would even take our case because all we wanted was the amount that John had put into the trailer. The only thing that we keep hearing is the permanent damage part. We were not even really concerned about that at first. Our lawyer called us back after he talked with our physician and told us that he could not say that permanent damage was done. We never did hear anybody say: "Find out if there was any per- manent damage done." PAGENO="0143" 139 So, I, myself, have found a doctor in our State and have made an appointment for John to go and have the test done. This is the only way we are going to be able to get legal counsel if there is perma- nent damage. If not, we will not have anything, nothing. We have until the end of this month and they are going to take that mobile home from us. Mr. ROSENTHAL. And then what happens? Mrs. LOVEJOY. I do not know. That is why we are here. We do not know what is going to happen. Mr. ROSENTHAL. Thank you. [The Lovejoy's prepared statement follows:] PAGENO="0144" 140 PREPARED STATEMENT OF JOHN AND CATHERINE LOVEJOY BEFORE THE COM~1ERCE, CONSUMER AND MONETARY AFFAIRS SUBCOMMITTEE MAY 18, 1982 This is a testimonial in regardè to a 1978 Festival Mobile Home purchased in November, 1977, by myself, John E. Lovejoy, now age 27. The mobile home was manufactured by Festival Homes of Ohio, Inc., a susidiary of Fleetwood Enterprises, Inc. For three years the home was occupied solely by myself and my daughter, Tracy, whom at the time the home was purchased was 1 year old. After this three year period I remarried and my wife Cather- me age 25, and my son Wesley age 3, then moved in. Soon after~ ward we found that my wife was pregnant with our now four month old son, Ian. During my first year of occupancy I began experiencing headS. aches, nausea, nasal congestion and recurrent vomitthg, which was severe enough to cause me to miss an abnormal amount of work. After experiencing this for a prolonged period of time, my concern lead tue to consult a physician. His diagnosis was sinus~ itus and he treated me for the same with no signs of improvement. My record shows that before this time I showed no signs of this type of illness. During this same three year period my daughter Tracy was also experiencing severe chest colds, coughing, ear infections and sore throats. Numerous visits to the doctor were to no avail and it PAGENO="0145" 141 lead to having her tonsils removed, which still did not eliminate the problem. When my wife and her son moved in the mobile home they started having the same symptoms which lead to their also seeking medical attention. Prior to their moving in there were no signs of any of the aforementioned problems. It was recommended that her sons ton- si-is also be removed. Circumstances at the time prevented us from doing so. Soon after our marriage it was learned that my wife was expect- ing a child. After experiencing no complications with her first pregnancy we fully expected this one to be normal also. However, she was in the hospital five different tines for emergency treat- ment. The major problem being, premature labor from November, 1931, until January, 1982, for which she was taking medication that caused severe-nervous side effects. -If the child had been allowed to come any earlier than he did he would have suffered ~ very low birth weight as his weight at term was only 6 pounds. After the baby was brought home he showed signs of the same - problems, i..e., runny nose, constant sleeping and breathing diffi.- culties. - We learned of formaldehyde poiseming through the media, and decided. to check to see if this could possibly be causing our problems. We contacted Dr. Charles Jordan, Ph.D., of Pikeville, Kentucky, who is a chemist. We were advised of the air content test and decided to have our home checked. Drs. advised us that in the meantime we should remove the baby immediately from that environment. - 97-153 0-82--lO PAGENO="0146" 142 After doing so the childs prob'ems disappeared in two days. The other children showed immediate signs of improvement also. After we ran the test ourselves we found a level of .1.2 ppm and .26 ppm. We were advised to seek legal counsel and to move from the mobile hone. Upon our moving from the mobile home our whole families improvements were dramatic. Through legal counsel we were advised to have the chemist, Dr. Jordan, to cone to our home and check the levels himself. Upon doing so, he found the levels to be what is considered to be extremely high. They were as follows: .54 ppm high living room .42 ppm high - master bedroom .38 ppm high childrens bedroom .05 ppm low outside To date, the emotional and financial stress have been over- whelming, we .have had to pay rent, plus we are still paying month- ly payments on the trailer and the lot rent the trailer is occupy- ing. We feel'.that after paying for a home for four~artd a half years that was some day to be ours and to have~: to turn about and start paying rent is distressing to say the least. The financial burden on our family in regards to medical bills have totalled well over three thousand dollars for this past year alone. This amount, of course, doesn't even cover our moving expenses. I believe the- aforesaid also explains the emotional difficulies. Finally, I would like to express the difficulty we have had in finding experienced legal and medical assistanceth regards to thisprobl.etn. The way we feel at the present time is that we have lost what took a long time to establish and hurt that these things are allowed to happen and families like ours are allowed to suffer. Thank You, (J~( John E. Lovejoy Catherine Lovejoy 411 Vine Street South Charleston, WV 25309 PAGENO="0147" 143 Mr. ROSENTHAL. Mr. Swanick, we are delighted to meet you. You may proceed. STATEMENT OF CHARLES SWANICK, ASSEMBLYMAN, NEW YORK STATE LEGISLATURE, REPRESENTING ERIE COUNTY Mr. SWANICK. Thank you, Mr. Chairman. It certainly is a pleasure to speak to you. Let me first explain that my involvement in this issue goes back to early 1980 when I received a number of complaints from resi- dents in my district concerning the use of urea formaldehyde foam insulation by various contractors. I must say my testimony will differ a little bit from the people who have spoken before. I did speak in the spring of 1980 before the State assembly task force of consumer affairs in New York State. The simple fact is that everything that I have heard here today is exactly what those people said to the chairman of that commit- tee at that time. I wholeheartedly agree with everything that has been said today. It basically follows the same concepts that I found since my in- volvement with this issue. Let me first just explain that we are very pleased about the Con- sumer Product Safety Commission ban most recently announced. To give you an example of our commitment to this issue, 2½ weeks before the Consumer Product Safety Commission was to make a determination as to whether the product was to be banned or not, in. the county of Erie, the State of New York, there was a $2-billion class action and individual suit filed on behalf of 23 resi- dents of Erie County and also a class action suit representing all the residents of the State of New York. This suit, and a cover letter, was sent to each member of the Consumer Product Safety Commission prior to their announcement of the ban. Also, this suit has been filed with four other States and there is intention that this lawsuit will be filed across the country on behalf of the people who have the problems associated with UFFI. It is a unique suit in the sense that it deals with both individual health problems and the problem of getting the product removed from the homes. It also deals with the health issues surrounding the future, the children that we see here today that have been dis- cussed, and their children concerning the health problems associat- ed with it. Richard Lipis, the attorney who is handling the Love Canal issue and lawsuits is the same person who is handling this. Mr. ROSENTHAL. Let me do this. Without objection, we will include your testimony in the record. What role do you think the Federal Government should be play- ing in this situation? Mr. SWANICK. First of all, we have to have a uniform testing pro- gram standard; In the State of New York we offer a free test. Many States do not have any testing program at all. Others offer tests that are incorrect. PAGENO="0148" 144 Right now across this country there are consumers who are get- ting the formaldehyde test done for the level of gas in their homes. The devices they are using for that test are incorrect. The only test right now that is being used and is supported is a test called the~ bubbler. It is a very simple device where you take a sample and you read it on a machine and it gives you back the per- centage. It goes to a low enough percentage so that a person who is very susceptible to formaldehyde gas will know that they have a prob- lem. We need-- Mr. ROSENTHAL. How would a person know if they are suscepti- ble to formaldehyde gas? Mr. SWANICK. Before the bubbler test was devised, as the test used, they used a Draeger device. That Draeger device level did not go low enough. Mr. ROSENTHAL. Just tell me this. How does a person know if they are susceptible? Mr. SWANICK. They usually will start to have problems that many of these people have discussed, such as headaches, dizziness, bloody noses. Mr. ROSENTHAL. Did you spend a prolonged period of time in the houses or did you go in for a quick visit? Mr. SWANICK. In some of the homes I have been to in my district that are heavily contaminated, I can go in there and automatically I will start to cough and feel a dryness in my throat. For the majority of the people who have the products in their homes-- Mr. ROSENTHAL. I am getting to a specific problem. Mr. SWANICK. And I am missing the point. Mr. ROSENTHAL. In your experience, you have walked into some of these homes and have stayed for how long? Mr. SWANICK. I have stayed for a couple of hours, 4, 5, 6, hours at a time. I have noticed a dryness in my throat. I have noticed some coughing and I have noticed I have started to itch a little bit. These are homes that have been tested and have a very high level of formaldehyde gas. Mr. ROSENTHAL. Like what? Mr. SWANICK. Like 0.35; 0.5; and so on. Mr. ROSENTHAL. What I am getting to is this. Maybe you can add something to this. The home that is outside has 0.38 parts per million in the kitch- en; 0.45 in the living room; 0.55 in the bedroom. If somebody went in there for a few minutes, around 12:15 today, would they have any reactions? Mr. SWANICK. Probably not. The reaction time varies with each individual. Mr. ROSENTHAL. But how would the individual know? Mr. SWANICK. Basically, the individual would not know. This is the problem with the homebuyer who purchases a home and puts urea formaldehyde foam insulation in their home. Mr. ROSENTHAL. Dr. Prisand, do you understand what I am talk- ing about? PAGENO="0149" 145 Dr. PRISAND. I am not sure. At those levels they might have watery eyes. They might present all the symptoms that we spoke about. My wife sat down a few weeks before we found out how widely formaldehyde was used. My wife was sitting with my day sheets from the office. That is where all my financial information is re- corded. She could not breathe. Her eyes started to run. Her nose started to bleed. It was not until 2 or 3 weeks later that we found out that the NCR paper has formaldehyde. Her symptoms came on immediately. There was a few minutes. The symptoms possibly could start in a matter of minutes of a sen- sitized individual. Mrs. LOVEJOY. I walked into a trailer this past Friday to deliver something to our friend. I almost fainted. I had to walk back out- side. Mr. KURZMAN. Perhaps, Mr. Chairman, the question is not to look for a symptom which everyone will have, but to look at the products which you know are off-gassing the formaldehyde. The National Academy of Science, when it determined there is no threshhold level for cancer exposure on formaldehyde, estimat- ed that there are 11 million Americans living in mobile homes who are at risk. Those mobile homes are built with particle board which off-gases formaldehyde. Formaldehyde does not exist to a very large extent in the general air environment. If you were to spend the afternoon or even the lunch hour in that mobile home, I would suspect if three or four people did it, in 45 minutes two of you would have eye irritation and throat irrita- tion. But that is not necessarily the way to respond. I would submit that in addition to testing, as suggested by the State representative from New York, we need to educate the physicians. I would also suggest that we need to eliminate the litigation and the advocacy. One side is saying, yes, it is and the other side is saying, no, it is not. Mr. ROSENTHAL. We are trying to find a mechanism to deal with this. I am sorry I interrupted you. Tell us again your recommenda- tions. Mr. SWANICK. The first recommendation is that we have to offer a test standard across the country that will insure that a resident who wants a correct test for formaldehyde gas, that it is done cor- rectly and that the results are given to them in a manner that they can understand and finally there should be at least an average price quote given-not set in any Federal legislation-but just to let them know basically what the going price is for this product, that is, for this test, to insure that they are not being overcharged for it. My second recommendation deals with this. We need some infor- mation, some published information, that can be provided to the residents who have this product in the home. PAGENO="0150" 146 Of course, it went nationwide when the Consumer Product Safety Commission banned the product. It was announced on all the radio and TV stations. The problem is that many people who have the product in their homes know very little about it. Yes, many of them have had health problems associated with it, but they really do not know what the product is, they do not know what formaldehyde gas is, and they certainly do not know how to remove the product from their homes. What we provided for you for your own reading is information that is provided by the Canadian Government. When the Canadian Government banned the product, they put these brochures together which they mail out to the residents. This one basically deals with the health problems associated with the product. It also explains how to take the product out of your home safely, and it gives the individual homeowner some informa- tion that is needed when he is looking for a contract or two to remove the product. Right now this kind of information is not available. I probably have a photocopy, at least 400 or 500 of these and mail them out on our own to provide that information. Again, the Canadian Government also talks about the price for removal of the product. I would ask that this information be placed in the record for your information. - Mr. ROSENTHAL. Without objection, so ordered. Mr. SWANICK. Finally, and most importantly, I think one reason why I am here is to discuss an issue that I am hearing all the time now since the ban has taken place, or just about to take place. We have people who actually are prisoners of their own homes. They have to live in that home and they have no way to get the product removed from their home. Right now the cost estimates in Erie County, N.Y., is somewhere between $10,000 and $20,000. Physically the inner wall or the outer wall has to be removed. The UFFI has to be removed. There has to be a scrub down of the boards by a liquid material, and then you have to reinsulate and put those boards back up. It is a very expensive operation. We have two groups of people. We have the group of people with UFFI who are having health problems. They almost physically cannot live in their homes. They want to get this product taken out of their homes as soon as possible so they can return back to a normal way of life. The other group of people are residents who are not having any health problems associated with UFFI, but because of the ban and because of the publicity of this product, they are now prisoners of that home because they cannot sell the home. Quite frankly I cannot think of any consumer who would pur- chase a home with UFFI in it at this time, or if there were, there would be just a few of them. So they cannot sell their homes and get a fair market value for it that they normally would have gotten before the ban took effect. Let me explain the concern of the UFFI in western New York' for a homeowner who wants to sell his home. The real estate"people PAGENO="0151" 147 and the bankers are now making the buyer and the homeowner sign a release form which releases those two groups from any liti- gation if that buyer were to become ill later on down the road or if there were a problem of litigation for the buyer and the seller. So you can see automatically that there is a problem associated with this. What the Canadian Government did when they banned the prod- uct they set aside x amount of dollars that would be direct grants to people who wanted to have their homes cleared of UFFI. I am not saying that we should do this. I realize the mood of Con- gress and the Washington problems that we are having across the country. I am not going for a grant. I would love to say I would like to get it, but I cannot. What I am asking for you to consider is low-interest loans. This way if we make these low-interest loans available to the public, the immediate problem is to get the product out of the home. This would accomplish that and it would be done in a manner that was safe and correct. I do agree that this material has to be taken to a toxic dump site. Fortunately in western New York we have one. Mr. ROSENTHAL. I am told that Congressman Conte of Massachu- setts introduced such a bill yesterday to provide low-interest loans. Mr. SWANICK. This may be the case. I am not privy to that infor- mation since I arrived here early this morning. I am not aware of it. But if that is the case, I am very pleased to hear that this has been brought to a legislative forum. The point here is that if those funds are made available, it will resolve the immediate problem. Hopefully the lawsuit-and I will discuss the New York lawsuit-when that is resolved in a number of years, if that is successful that will provide the compensation to pay for these low interest loans. Mr. ROSENTHAL. I am afraid we do not have the time to go into that. Again, tell me. What do the Canadians do? Mr. SWANICK. The Canadian Government set up a fund and that fund is used for direct grants. Mr. ROSENTHAL. Not loans? Mr. SWANICK. No, these are direct grants. These are not loans. Mr. ROSENTHAL. Is there any limitation per family? Mr. SWANICK. Yes, $5,000 per family. This loan is provided to~ them to use- Mr. ROSENTHAL. Is it a grant or a loan? Mr. SWANICK. It is a grant. It is given to them free. Mr. ROSENTHAL. If they satisfy certain requirements? Mr. SWANICK. Yes. It is solely used for the removal of urea formaldehyde foam insu- lation in their homes. That was after the Canadian Government banned it. We are taking a middle-of-the-road stand with low-interest loans. Mr. ROSENTHAL. How do you help the Lovejoys with a low-inter- est loan? PAGENO="0152" 148 Would that solve your problem if you could get a low-interest loan? Mr. LOVEJOY. No. Mr. ROSENTHAL. Why not? Mr. LOVEJOY. I do not think we could live in the mobile home even if it were refurbished right now because of the mental an- guish we have been through. I do not think we would ever return to it. There has been so much heartache associated with it. Mr. ROSENTHAL. People have been in such severe financial straits that I do not see how a low-interest loan will help most of these people who are wiped out. Mrs. Geller, would it help you? Would a low-interest loan help you? Mrs. GELLER. Only if it was enough for us to repurchase a home. I have no home or land at this point. Mr. SWANICK. What we are finding now since the ban and with the group of about 500 people in Erie County right now who have this problem, their situation is not as advanced as the people that are speaking here today. They have the health problems. They also have a reason to try to sell their home. The problem is that they cannot get the product taken out of their home because they cannot afford it. Frankly, the average consumer does not have $10,000 to $20,000 to pay to have this product taken out safely. So for these people they are locked into living in their homes and they are actually prisoners of their homes. I have no problem with direct grants such as the Canadian Gov- ernment is providing. It is just my concern that with the mood of Congress as it is, I am looking for some help. My alternative would be to go to low-interest loans because that would be less of a burden to the Federal Government. Mr. ROSENTHAL. Mr. Barnard. Mr. BARNARD. Thank you, Mr. Chairman. What has the Canadian Government done about other uses of formaldehyde and other types of products which use formaldehyde? What have they done about that? Mr. SWANICK. The Canadian Government looked very closely at mobile homes. They are another group of homes that most do not have urea formaldehyde foam insulation, but they have a lot of particle board in it which formaldehyde is used in that production. They also have restricted the use of formaldehyde as a product throughout Canada very restrictively to reduce the problems that these people are having right now. Mr. BARNARD. Only in building products? Mr. SWANICK. Basically in building products. Formaldehyde is everywhere. You will hear this somewhere along your opportunity. You have it in carpeting. You have it in plastic garbage bags. But the real problem with this issue is that when you put for- maldehyde insulation around the walls of your home or when you are in a home that has a lot of particle board, and when the major product used for that is formaldehyde, you get a tremendous amount of off-gassing. PAGENO="0153" 149 That gives you the high levels. These people are sensitized to for- maldehyde and other chemicals. So they have a very unique prob- lem. For the average person who has not reached their point yet, they will find that they have the headaches, the runny eyes, the sore throat and so forth, but they have not become sensitized. Sensitized is another step in this issue. Mr. BARNARD. So the Canadian Government-their action only applies to formaldehyde in the use of insulation and building prod- ucts. It has not gone to the use of formaldehyde, as you said, in gar- bage bags, cigarettes, perfumes, deodorants and things of that kind? Mr. SWANICK. From what I understand with the insulation issue, that is what I have been deeply involved in. The Canadian Govern- ment did not involve itself directly in those other products such as perfumes and plastic bags and so forth. But they have set limits on the off-gassing of formaldehyde. When they set those limits that did reduce the use of formaldehyde in carpeting and other products. But I am not sure specifically if it reduced the make-up of a ciga- rette, for example, or perfume. This is something that we need. Our State Health Department right now used to use a level of 0.05 as a level of telling the resi- dents whether they have a problem or not. Now our State Health Department will not even use that per- centage. They simply give the people the result with no recommen- dation. There is such a concern now since the product has been banned. That is why I say we need a health standard level across this coun- try so that it can give these people something to deal with. Mr. BARNARD. Generally how are people allergic to formalde- hyde? We have some folks who are allergic to pine trees and to pollen and things of that kind. It reacts unfavorably. Is there some kind of a medical examination that you can have in order to determine your system's attitude toward formaldehyde? Mr. SWANICK. Yes, there is. Unfortunately many doctors really are not aware of the formal- dehyde gas and formaldehyde issue. I agree when they said they had to explain to the doctor what this was all about. We have one doctor in western New York who is an expert on this issue. Unfortunately she charged between $100 and $150 an hour for help. The average citizen finds that very difficult to afford. But she has worked out a series of tests which she runs. They are very extensive. She can pinpoint formaldehyde gas as the cause of the problem, the health problem that the people are having. Again, unfortunately, it is very expensive and most people cannot afford it. The point here, I think, is this. Because this issue has become such a public issue now, people are aware at least of some of the symptoms. There is now a public awareness and people who have been sick for a long, long time-there is a woman I know who has over PAGENO="0154" 150 $2,500 in medical bills for her children. She has been going through this for 2½ years. She never had any idea of what it was. A doctor was never able to pinpoint the problem. When the story broke about the UFFI on "20/20," she started to go through the tests. They are now convinced that her problem is formaldehyde gas. Mr. BARNARD. What is the level of formaldehyde that the aver- age person would not be affected by? Mr. SWANICK. This is the problem. Formaldehyde gas is unique to each individual. Our sensitivity levels vary from person to person. When the State of New York went to the bubbler test, it went there for one reason. Each person has a different level. The bubbler test starts out at 0.01 and will go up to a higher level. In this way, prior to the bubbler test, when they used the Draeger test, the level did not go high enough. So they would say: "Well, we do not find any formaldehyde gas in your home." People had the same problem with formaldehyde poisoning but were told that they did not have any readings. Then when the bub- bler test came out and they were retested, they found that they had levels of formaldehyde gas in their home. So that is the major problem here. When one says: "Well, what is the average level? What are the average symp- toms?" The problem then is that the level of gas affects every person dif- ferently. I have been in homes that those people have not had any problems with formaldehyde poisoning. They have UFFI. They have had people to come and stay with them, guests for a matter of 1 week to 2 weeks, and those guests have become deathly sick. It is because of formaldehyde gas. There are families where the children can be deathly sick and the adults are healthy and fine. It can be just the reverse. That is the problem with this product. The fact is that you cannot control the installation of it and you cannot control the effect of the off-gassing to each individual. That is why the bottom line for the consumers and the individual homeowners, at least where I live, their bottom line is: "I want that product out. I want it out as fast as I can. I will deal with the compensation later, either through the courts or whatever it takes." I have people right now that are taking their life savings, in excess of $10,000 and paying to have a contractor remove that product. Mr. BARNARD. I am trying to see how universal the problem is. We have people who will sell everything they have to move to Ari- zona just because of the plain atmosphere in a community. I am trying to determine this in my own mind. I am very sympa- thetic with all of the people who have testified this morning and how they have been affected. They have pretty much been able to pinpoint their degree of suffering as to this. But on the other hand, what I am trying to say is that I am just wondering how universal it is. PAGENO="0155" 151 There are a lot of things in the atmosphere that will affect a person according to his own individual anatomy. Mr. SWANICK. I agree with that. But let me add one thing. Think about the atmosphere and how large it is and how much air flows through it. Think about your own household in the middle of the cold months of the winter when all the windows are closed, when your furnace is on and all it is doing is recirculating the air. Anyone who stays in that home, such as a wife, a child, or if you do most of your work at home, if you have formaldehyde gas, large quantities, or a small quantity, being released into that home, you may be adversely affected. The point I am saying is this. You cannot compare the environ- ment of our society or the universe and compare it with the UFFI problem. You are putting 6 inches of formaldehyde products, formalde- hyde gas, in between your walls. And then you are physically clos- ing all the windows in the cold months and living in that environ- ment. You and I both know that the air in a home does not change dra- matically during the winter months because of the enclosures, the ceiling, the insulation, and so forth. Mr. BARNARD. So much of this condition then would be in cold climates? Mr. SWANICK. No, not really. We have found now this product was also used for insulation in the States where it is very warm because of the air conditioning costs. So it is a universal, across-the-country problem. In the Northeast, sure, for the winter months, that is what it was put in there for. In the Southern States and in the Western States, where it is a little warmer, they use it for an air-conditioning product to cut down the use of those air-conditioning devices. Mr. BARNARD. Thank you, Mr. Chairman. Mr. ROSENTHAL. Mr. Hiler. Mr. HILER. Thank you, Mr. Chairman. I would like to direct a question or two to the majority counsel. Regarding the test that was conducted last evening in the mobile home, was the home in its normal state? Was it plugged in, were the circulating fans going when the test was conducted? Mr. ROSENTHAL. We will have the experts testify. Mr. HILER. Are they the people who conducted the test? Mr. ROSENTHAL. I do not think we need that for the record, but we will have it tomorrow. Mr. HILER. We were comparing numbers, and I think we need to get the base numbers which were used here. Mr. ROSENTHAL. I just wanted to know if it was safe for me to go in there. [Laughter.] Mr. SWANICK. Mr. Chairman, I have one favor. When you find out the analysis results of the tests, find out what test was offered. Please be very careful. The bubbler test-- Mr. ROSENTHAL. We will have them testify. Mr. SWANICK. OK; I just want to insure that it was the right test. PAGENO="0156" 152 Mr. HIn~R. Mr. Swanick, concerning the people in Erie County you are talking about, are they in manufactured homes, site-built homes, office buildings, or what? Mr. SWANICK. Basically they are in two types of homes. One is the mobile home and the second is their own home which they have had urea foam insulation put in as an insulation. Mr. HILER. And therefore, a manufactured house does not use UFFI; right? Mr. SWANICK. According to our study, until recently when the ban went across the country, they were putting UFFI in up until that date. In fact, the ban is not in place just yet. It is being used in areas where it has not been well publicized. Mr. HILER. And it is being used as an insulation material in the walls? Mr. SwANICK. Yes, sir. Mr. HILER. It is also used in a great many office buildings as well? Mr. SWANICK. In western New York; no. It has not been used as extensively as it was in the private homes. The reason is that in 1976 this product started to be used more extensively because, of course, Congress was moving more toward using tax rebates and so forth for insulation. That gave the homeowner an opportunity to write something off on their taxes. So, from 1976 to 1980, our building construction in western New York has been somewhat slow. Of course, our housing construction has been slow also. But the person who owned an existing home who was out to try to cut some of the costs of energy, they were the ones who went ahead and spent those dollars to get the home insulated. That is what we found that most of the problems being associat- ed with UFFI in present existing homes that had the product pumped in. Just for your own information, another reason why there were so many problems associated with this problem in 1976 forward-that is when the Consumer Product Safety Commission started issuing bulletins, if you study the product itself, there are different types of resins that were available. These are people who are invOlved in the industry that installed the product and who have talked with me. What happened is this. In 1976, because there was such a demand for it, some of the resins that were used were of a cheaper quality. Their shelf life was not nearly as long as some of the original resins that they used. So for small businessmen and installers, they would buy this at the cheapest time and store it. Unfortunately some of the resins would sour on the shelf and then it would be pumped in. Of course, people then began having problems. That was one reason why part of 1976 there were not too many cases, at least documented cases, of formaldehyde poisoning. But after 1976 and the Nation as a whole started using the product, that is when the product problems started to show up. PAGENO="0157" 153 Mr. HILER. There are different kinds of formaldehyde used in homes. Have you found that most of the problems associated with UFFI are related to vaccines and antiperspirants, or the draperies and the upholsteries that contain formaldehyde? Mr. SWANICK. I am going to be very, very honest about that statement. The problems that we found in western New York are associated with two things. One is the use of urea formaldehyde foam insula- tion in homes. Second is the use of particle boards in mobile homes. The high level of formaldehyde gas that is released in those homes-I could sit here and debate the formadehyde levels being released by a plastic garbage bag in your home or a cigarette or perfume. For somebody who is sensitized, it is a very serious problem. I re- alize that. But for the majority of the people I know-and I would say prob- ably somewhere between 500 and 600 residents-there problems are associated with those two products. They have not reached a level of sensitivity that these people here today have. Mr. HILER. Given the fact that it may not be the formaldehyde in the plastic bags, or the vaccines, or the antiperspirants, but rather in specific products where we may find the problem to be most acute, do you think we should develop product standards, then, that would be oriented toward specific products as opposed to es- tablishing air quality standards? Mr. SWANICK. I think to lead with what the Canadian Govern- ment does, certainly there is a year and a half of background that they have already had in place. I think an excellent idea would be to set levels of formaldehyde gas, and set those for products at least in the beginning, as the Ca- nadian Government did, to try to control the use of this product across the country. Mr. HILER. So what you would recommend then is to set a stand- ard based on the leaching of the formaldehyde from a particular product? Mr. SWANICK. Yes, that would be an area that I would pursue. I have not had one complaint-and we have had complaints across the country now on this issue-from an average citizen con- cerning the leaching of formaldehyde gas concerned with garbage bags or those smaller items. Mr. HILER. Normally, homes usually contain 0.1 to 0.2 parts per million. Is that not substantially higher than the threshhold level that you suggested the State of New York set at 0.05? Mr. SWANICK. You have to go back to the sensitivity level of indi- viduals. The State went to 0.05 because there were people who were having, or appeared to have the effects of formaldehyde gas, health problems. They went to a low level to find out if there was formaldehyde gas in the homes. That is when it showed up. That is when they had a level and that is when they started running the test and were able to lock the level in, the formaldehyde gas leaching into the homes and the level of the test. PAGENO="0158" 154 Mr. HILER. Mainly it has been from the UFFI insulation and the-what was the other? Mr. SWANICK. Mobile homes-the use of particle board used in close areas. Formaldehyde is used extensively in particle board and it does off-gas. We have results in Erie County and Monroe County-Monroe County has done their own testing program-with the mobile homes that clearly indicates the association between the two prod- ucts and the formaldehyde gas poisoning. Mr. HILER. You say, in your understanding of the problem in western New York, that there are great differences in sensitivity levels among the public at large? Mr. SWANICK. Yes, this is the hardest thing to explain to anyone of how a parent can be perfectly healthy in a home and their chil- dren can be deathly sick, or one parent is very healthy and the other parent is very sick. It has taken from 1976 when the first reports started to show up concerning formaldehyde gas, up to today. All the tests that have been done, all the scientific research, finally has come out with a reasonable assumption that we all have different levels of sensitiv- ity. That is the marked reason why members and families can show different types of levels of illness, although I must say the symptoms, the beginning symptoms, are pretty much universal concerning formaldehyde gas. Mr. HILER. I yield back the balance of my time. Thank you very much. Mr. ROSENTHAL. Mr. Daub. Mr. DAUB. I only want to say that I am most appreciative of this opportunity to become aware of the concerns addressed by these hearings. I apologize I could not be here for the early part of your testimo- ny. I look forward to reviewing that. Mr. Chairman, I think this is a worthwhile endeavor. I appreci- ate the opportunity to participate in the hearing. [Mr. Swanick's prepared statement follows with the exception of the complaint which is on file in the subcommittee office.] PAGENO="0159" 155 TESTIMONY OF CHARLES M. SWANICK Erie County Legislator Kenmore, New York PRESENTED TO HOUSE OF REPRESENTATIVES SUB-COMMITTEE ON COMMERCE, CONSUMER, AND MONETARY AFFAIRS Washington, D.C. May 18, 1982 PAGENO="0160" 156 I NTRODUCTI ON Chairman Rosenthal and distinguished members of the Sub-Comittee, my name is Charles M. Swanick. I am a member of the Erie County Legislature in upstate New York. My district covers the town of Grand Island, the, village of Kenmore, and parts of the City of Tonawanda and the Town of Tonawanda. I represent about 60,000 people. In my legislative capacity, a number of my constituents and other residents of Erie County have brought to my attention various health problems which they felt were incurred by exposure to formaldehyde gas that was off-vented from the urea- formaldehyde foam insulation which had been installed in their homes. Based on these complaints, I began investigating the extent to which this was a problem. My investigation uncovered what I consider to be very alarming results. I discovered that: * Urea-formaldehyde is a significant health hazard to those individuals who have jnstalled this product in their homes. O Consufners who purchased this, insulation did so without any appropriate. warning or knowledge of the health hazards involved. * Many consumers placed this product in their homes following recormnendatioflS from the Federal Government which urged people to insulate as a method of reducing energy usage. * There are no uniform standards set for testing and evaluating the extent to which off-vented gas is a problem in a home. I believe that it is the responsibility of governrrient to set standards for testing and to provide homeowners with urea-formaldehyde insulation some assistance in alleviating their problem. This assistance could be in the form of a tax credit or low interest government loans which would make it financially feasible for these people to have this dangerous substance removed from their homes. PAGENO="0161" 157 INVESTIGATIVE CHRONOLOGY I received the first complaint in the spring of 1981 from Michael and Elizabeth Smith who own a home in the Town of Tonawanda. On June 23, 1980, they had signed a contract to have urea-formaldehyde insulation installed in their home. The day before they signed the contract, a law went into effect in New York State which states: Any person, firm or corporation which sells or installs urea-formaldehyde foam insulation shall give written notice to the purchaser of such insulation or the owner of the building wherein such insulation is installed, stating as follows: THIS INSULATION IS UREA-FORMALDEHYOE BASED AND MAY EMIT FORMALDEHYDE. AFTER INSTALLATION OF THIS PRODUCT, SOME PEOPLE HAVE EXPERIENCED ADVERSE PHYSICAL EFFECTS FROM FORMALDEHYDE EMISSIONS, INCLUDING UNPLEASANT ODOR, WATERY EYES, AND NOSE AND THROAT IRRITATIONS. THESE CONDITIONS MAY BE ALLEVIATED BY INTRODUCING FRESH AIR INTO THE BUILDING. EXPOSURE TO UREA-FORMALDEHYDE FOAM INSULATION IS NOT RECOMMENDED FOR PERSONS WHO HAVE BEEN PREVIOUSLY SENSITIZED TO FORMALDEHYDE, OR WHO HAVE A HISTORY OF RESPIRATORY PROBLEMS. UREA-FORMALDEHYDE INSULATION IS NOT RECOMMENDED FOR USE IN ATTICS, BELOW GRADE OR WALL CAVITIES DEEPER THAN SIX INCHES. UREA-FORMALDEHYDE FOAM IS NOT RECOMMENDED UNLESS THE OUTSIDE VERTICAL WALLS HAVE AN AIR SOURCE." None of this information was written into the Smith's contract. On July 25, 1980 the insulation was installed into their home. As soon as their home was closed for the winter, 28 year old Elizabeth Smith became ill. She had never had similar problems before. There were no allergies or sinus conditions in the family's medical history. Mrs. Smith's illness lasted eight weeks. Her symptoms included bad coughing, breathing difficulty, facial pain, depression, and irritability. Medications prescribed by her physician and by an ear, nose, and throat specialist were not effective. 97-153 0-82--li PAGENO="0162" 158 The Smith's two children were also sick. The only thing that helped to alleviate the problem was to leave the house which seemed very strange to the Smiths because winter temperatures were often below freezing. In the early spring of 1981, a friend told the Smiths about a Canadian television broadcast which discussed the health hazards of urea-formaldehyde foam insulation. It was the first indication they had that their health problems might be related to the insulation'~ihich had been installed in their home thesurrmer before.' Not knowing where to turn for help, the Smiths wrote a letter to me. I began my investigation by contacting the New York State Health Department for information. I was told that urea-formaldehyde insulation was causing health complaints in the State and that the Health Department provided a free testing service to residents who suspected that there was a high level of off-vented gas from their formaldehyde insulation. I then went to Monroe County in Upstate New York to talk to the County Health Comissioner. He told me that Monroe County instituted its own testing program and they were fir~ding high levels of off-vented formaldehyde gas in the homes in the Rochester, New York area. Many of these homeowners were ill. I imediately wrote to the Consumer Product Safety Comission. When I saw the over~ihelming evidence that urea-formaldehyde insulation could cause serious health problems, I scheduled a public meeting for residents of my district whose homes were insulated with urea-formaldehyde foam. Twenty-three homeowners attended the first meeting and decided to form a citizens group. The group hired attorney Richard Lippe~s of Buffalo to investigate the possibility of instituting individual and class action law suits against the installers and manufacturers of urea- formaldehyde foam insulation. PAGENO="0163" 159 On May 4, 1981, Mr.and Mrs. Smith and I testified before the New York State Assembly Consumer Affairs and Protection Committee. We asked for a temporary ban of urea-formaldehyde insulation. The ban was not instituted but the State did propose stricter labeling legislation to warn consumers of the health hazards associated with the problem. Before the legislation was passed however, the Consumer Product Safety Commission banned the product nationwide. Several weeks before the Consumer Product Safety Commission announced the ban, the citizens group which was led by Michael and Elizabeth Smith, announced that they were bringing individual and class action suits for $2 billion against manufacturers and installers of urea-formaldehyde insulation. Originally there were 23 homeowners involved in the law suit. Now there are more than 450. EFFECTS OF THE CONSUMER PRODUCT SAFETY COMMISSION BA~ No purpose would be served in reviewing the scientific evidence which led to the Consumer~Product Safety Commission's ban of urea-formaldehyde foam insulation in residential properties. I am sure that each of you is familiar with the Commission's action and the basis for that action. However, I would like to point out that this action wasnot taken quickly or arbitrarily. The Commission thoroughly studied the health effects of the product as well as the economic effects that a ban would have on the urea-formaldehyde foam industry. The members of the Commission are not known to be tough on industry' or in any fashibn biased in favor of a consumerist, environmentalist, or liberal view- point. The fact that the Commission members determined that the only effective alternative was to ban the use of the foam indicates in a most startling way that urea-formaldehyde insulation is a substantial health hazard. PAGENO="0164" 160 There was one aspect of the ban that may not have been as carefully thought out, however. That aspect is the effect which the ban would have on the public. Those of us who live in Western New York are highly sensitive to issues concerning exposure to hazardous substances. The notorious Love Canal landfill' is only about 15 miles from my district's borders. Western New Yorkers have viewed the plight of the Love Canal residents with both horror and alarm. The same type of trauma that was involved with Love Canal is being experienced by those people who have urea-formaldehyde foam in their homes. Just as theLove Canal residents felt trapped in their homes, urea-formaldehyde foam homeowners also feel imprisoned because they don't have the financial resources to have the substance removed or to relocate to alternative housing. Just as in the Love Canal situation, there is no ready market for selling their homes because of the urea-formaldehyde insulation. Prospective buyers simply do not want to purchase a home with foam in it and many of the residents feel that they have a moral obligation not to sell their home to someone who would be faced with the same health risks that they are seeking to avoid. The homeowners feel trapped. They are exposed on a daily basis to an insidious chemical which they cannot see, and in most homes, cannot smell. They have been told by the Federal Government that this substance causes acute and adverse toxicological effects including eye, nose, and throat irritations, chronic coughing, chronic head- *aches, chronic nausea, dizziness, drowsiness, lapse of memory, bronco-pneumonia, pulmonary edema, other respiratory and neurological injuries, allergic reactions and hypersensitiVity to allergies. In addition, they are being told that exposure to the formaldehyde will put them and their children at a greater risk of contracting cancer and that exposure may cause mU~agenic disorders in future generations of their children. Therefore, it is not surprising that these homeowners have undergone great trauma and their phobic reactior remaining in these homes is understandable. PAGENO="0165" 161 The Federal Government, through the Consumer Product Safety Commission ban, *has taken an appropriate response to assure that no further homeowners are faced with the same health risks through exposure to off-vented formaldehyde gases from the insulation. But the Government has provided absolutely no remedy for the homeowners who have already incurred this risk, and whose health has already been adversely affected. If the Government owes any responsibility to its citizenry, its highest responsibility should certainly be to protect their health. When added to these general governmental responsibilities, the fact that the Federal Government had encouraged the use of urea-formaldehyde foam insulation during the energy crisis, simple equity in justice would indicate that some remedial measures should be carried out by the Federal Government for those homeowners who, as good citizens, attempted to do their part to reduce energy usage by insulating their homes with urea-formaldehyde foam insulation. - Other governments have provided such remedial measures for their citizens. As I am sure you are all aware, the government of Canada has provided a low-interest loan programto homeowners with urea-formaldehyde foam insulation so they can have the foam removed from their homes. The State of Massachusetts has attempted to force the installers of this foam to remove the foam from those homes which have been found to be unsafe, although this action has recently been overturned by the courts. I believe that the Canadian approach is the most reasonable. If applied in the United States, it would have only minimal economic impact on the budgetary process, but it would go a long way toward reducing the trauma incurred by individuals who fear for their health and the health of their children. PAGENO="0166" 162 ALTERNATIVE REMEDIES There are several other potential alternatives which government could provide to remedy this problem. The United States could establish a grant program so that homeowners could have the foam removed at no cost to them.. However, given the current budgetary restraints upon this Congress, I believe that such a program would be politically unfeasible and perhaps not in the best interests of this country's economy. Another alternative available to these residents is to pursue litigation against the installers and the manufacturers of urea-formaldehyde insulation. As I mentioned earlier, many residents in New York State ha~e already engaged attorneys to bring lawsuits on their behalf and Mr. Richard Lippes, an attorney in Buffalo, has recently filed a Class Action on behalf of the 70,000 to 130,000 homeowners who have urea-formaldehyde insulation in New York State alone. The foam industry estimates that there are approxiamtely 450,000 homes with this type of insulation nationwide. - Mr. Lippes has indicated to me that similar lawsuits will be filed in the states of Maine, Connecticut, Michigan, and Missouri in the next month. Lawsuits are also being considered in Ohio, Oregon, California, and several other states. While Mr. Lippes has indicated that he believes these lawsuits will ultimately result in a successful conclusion, litigation of this nature is costly and takes a significant amount of time before the lawsuits will be completed. He estimates that it cou~d take as long as six to ten years. During this time, the homeowners will continue to be trapped their homes. Removal of the foam is a major project which costs somewhere between $10,000 and $20,000 depending on the way in which the home was constructed. Residents who PAGENO="0167" 163 cannot afford to have the foam removed and cannot afford to move to another home, will face continued exposure to this health risk. While litigation may ultimately provide these residents with their most effective remedy in terms of compensation for adverse health effects and for any property damage, the lengthy delays involved make this alternative unacceptable unless some additional program is implemented which will provide these people with a means of removing the foam while they wait for the final determination of the lawsuits. I respectfully submit that the approach similar to that taken in Canada, along with the litigation remedies available to these homeowners, would allow for the most reasonable and cost-effective remedy to the problem. If the Federal Government were to provide low interest loans to residents with urea-formadehyde insulation, those residents would defray the costs of the program as the loans were repaid. Economic and budgetary impact upon the Federal Government would be minimal. Recently, the Erie County Legislature passed a resolution asking the Federal Government to provide this type of assistance to homeowners with urea-form&ldehyde insulation. lam submitting a copy of that resolution for your information. CONCLUS ION As stated previously, if government owes any responsibility to its citizenry, it is certainly to protect their health and welfare. Urea-formaldehyde insulation is a disaster to those homeowners who have purchased it just as surely as if they had been placed in the path of a hurricane or in the midst of an earthquake. This PAGENO="0168" 164 country has recognized natural disasters in the past, but with the exception of the health emergency order issued to Love Canal residents, governmental response to man-made disasters has not been as fully developed. The low interest loan program may be the only cost effective manner in which we can alleviate these citizens problems. It would go a long way toward assuring that these people will not incur any further adverse health consequences from exposure to formaldehyde gases. Thank you for considering these observations and proposak. Respectfully submitted, May 18, 1982 CHARLES M. SWANICK Erie County Legislator Kenmore, New York PAGENO="0169" 165 ISSN 0701-5216 UREA FORMALDEHYDE FOAM INSULATION: PROBLEM IDENTIFICATION AND REMEDIAL MEASURES FOR WOOD-FRAME CONSTRUCTION Division of Building Research, National Research Council of Canada Ottawa, August 1981 NO. I National Research Conseil national Council Canada de recherches Canada PAGENO="0170" 166 PREFACE This is the second Building Practice Note on urea formaldehyde foam insulation (UFFI) to be issued by the Division of Building Research, National Research Council of Canada. The first, "Urea Formaldehyde Foam Insulation," BPN 19, is recommended as a general overview of the product and potential problems. This document has been prepared to meet the demand by consumers and contractors for guidance in solving problems related to UFFI. The need to provide immediate information has not allowed for intensive research or extensive field trials of the remedial measures presented. The properties of the UFFI in a particular house, the sensitivity of the occupants, and the building characteristics will all affect the potential for or the type and severity of problems. It is stressed that no two houses, occupants or UFFI installations are likely to be the same and therefore the success of remedial measures will vary. The remedial measures presented are based on the current knowledge of the behaviour of UFFI and on building science principles. Application of the remedial measures to the wide variety of houses experiencing problems is limited. The procedures may be simplified or supplemented for one or more types of construction as experience is gained and more information becomes available. The effects of seasonal changes in weather conditions on the performance of the many forirulations of UFFI in relation to the formaldehyde and other gas concentrations in the living space are not yet fully understood. In relating the extent of remedial measures to measurements, every attempt has been made to err on the safe side. If doubt remains as to the seriousness of a situation, additional measures should, be undertaken. In some cases the services of a consulting engineer or architect will be required to assist in diagnosing a problem and selecting remedial measures. The term "formaldehyde gas," as used in this document, refers to the mixture of gases released by UFFI; formaldehyde gas is usually dominant. Since this composition of gases may vary from product to product the gas is difficult to characterize and might be called "UFFI gas." For simplicity, the gas is referred to as "formaldehyde gas" but it should not be assumed that it is the same as pure formaldehyde gas or that the limits for exposure are necessarily the same as for the pure gas. As no animal exposure tests have been conducted on "UFFI gas" it would be prudent to keep exposures well below the maximum exposures for pure formaldehyde gas. The recommended minimum remedial measures are based on the dominant gas, formaldehyde. The majority of these measures should, however, reduce the infiltration of "UFFI gas" into the living space. The examples presented in Appendix A are based on a number of actual cases, but have been simplified to illustrate the use of the remedial measures outlined in the tables. ` . (i) PAGENO="0171" 167 Table of Contents Page No. 1.0 INTRODUCTION . 1 2.0 PROBLEM IDENTIFICATION 2.1 Medical Symptoms 3 2.2 Formaldehyde Gas (Odour) and Its Entry into the Living Space 3 2.3 Moisture in the Insulated Cavity 5 2.4 Visible Indications of.a Problem 6 2.5 UFFI Locations Requiring Special Consideration.... 7 2.6 Measurements of Formaldehyde Gas 8 2.7 Summary -. Problem Identification 11 3.0 REMEDIAL MEASURES 3.1 Principles of Remedial Measures 12 3.2 Sealing the Inside Surface of the Exterior Walls 18 3.3 Increasing Ventilation by Use of Forced Air Furnace Fan or Windows 21 3.4 Forced Ventilation 22 3.5 Air Filter System 23 3.6 Removal of UFFI from Wall Cavities 25 3.7 Removal of Residual Formaldehyde from the Living Space 30 3.8 Summary - Remedial Measures 31 4.0 PREVENTIVE MEASURES 32 5.0 PROTECTIVE MEASURES FOR WORKERS 32 6.0 CONCLUSIONS 33 REFERENCES 34 APPENDIX A- Selection of Remedial Measures Tables Al to A4. Action Steps and Remedial Measures for the Following Conditions: Table Al - Moisture Content of Wood over 20% Table A2 - No Medical Problems, No Odour from UFFI Table A3 - Odour from UFFI Present Table A4 - Medical Symptoms Apparently Related to IJFFI APPENDIX B- Summaries of Subjects to be Covered by Future Publications on UFFI 1. Measurement of Moisture content of wood 2. Measurement of Formaldehyde in the Living Space 3. Measurement of Formaldehyde in the Wall Cavity 4. Test Opening and Material Sampling 5. Optical Probes 6. Drying a Wet Cavity (ii) PAGENO="0172" 168 APPENDIX C- Fungi Isolated from UFFI APPENI)IX D - Types of House Construction INDEX LIST OF FIGURES Page No. Figure 1 Potential air leakage paths in a wood-frame house.. 4 Figure 2 UFFI in~talled in cathedral ceiling 7 Figure 3 UFFI in floor overhangs 9 Figure 4 UFFI in joist spaces in balloon-frame construction. 9 Figure 5 UFFI in basement wall 9 Figure 6 Simplified pressure diagrams for houses 13 Figure 7 Flows of formaldehyde gas through a living space 15 Figure 8 Accumulated effects of remedial measures on formaldehyde gas concentration in living space 17 Figure 9 Sealing wall/floor junction with sealant 19 Figure 10 Sealing wall/floor junction with pipe wrap . 19 Figure 11 Sealing wall/floor junction with flexible weatherstripping 19 Figure 12 Fresh air intake 21 Figure Al Relationship of formaldehyde gas concentration in wall cavities, temperature and relative humidity to class of UFFI Figure BI Test opening Figure Dl Platform frame construction Figure D2 Balloon frame construction Figure D3 Plank frame construction Figure D4 Solid masonry construction (iii) PAGENO="0173" 169 UREA FORMALDEHYDE FOAM INSULATION Problem Identification and Remedial Measures For Wood-Frame Construction by R.P. Bowen, C.J. Shirtliffe and G.A. Chown The National Research Council of Canada and any person acting on its behalf assumes no liability arising from the use of the information contained in this document nor warrants that such use will be free from privately owned rights. 1.0 INTRODUCTION Urea formaldehyde foam insulation (UFFI) is a foamed-in-place material which has been used primarily for retrofitting residential buildings. In some but not all homes with UFFI, there is evidence of formaldehyde gas emissions from the insulation and fungal growth in the insulated cavities. In some of these homes, one or more household members have experienced adverse health effects believed to be related to the presence of the UFFI. The presence of UFFI in the building enclosure does not mean that the foam has caused or will cause either excessive formaldehyde gas emission or fungal growth. Occupants of homes insulated with UFFI who suspect that problems already exist, anticipate problems because of faulty application, or who just want to have the performance of the material investigated, should have their houses checked. Remedial or preventive measures should be undertaken to reduce the severity of existing problems or reduce the possibility of future ones developing. All measures taken should be documented (including photographs) for future reference. This publication discusses some procedures that may be followed by the homeowner, contractor, or UFFI manufacturer in diagnosing the conditions in a home and identifies some measures that are remedial or preventive in nature. To date, experience with diagnostic procedures, and remedial and preventive measures has been somewhat limited. Because of the prevalence of wood-frame construction in Canada, the remedial measures discussed here are related only to this type of building. The principles described for both diagnostic and remedial measures, however, can be applied to other types of construction such as masonry. At present, the removal of UFFI from masonry cores or cavities is unlikely to be either effective or feasible. Other remedial measures may have to be selected until new methods of removal are developed. The magnitude and type of problem encountered, as well as the sensitivities of the occupants, will be factors in the selection and extent of remedial measures used for a particular house. Each house and PAGENO="0174" 170 -2- Lroblem will be unique in some aspects and must be thoroughly investigated before initiating remedial measures. Constant vigilance must be maintained for extenuating factors that might necessitate changing the procedures. The investigation should include measurements of the formaldehyde gas concentration in the insulated cavities and, when applicable, in the living space, and the moisture content in a series of wall cavities. These and other investigatory procedures are discussed in Section 2. In some cases the measurements are repeated during or after the remedial measures to provide an indication of the effectiveness of the measures. Remedial measures for wood-frame construction range from increasing the fresh air supplied to the living space to removal of the UFFI. These measures are described in detail in Section 3. In most cases a series of remedial measures is recommended. For a specific house, the selection of the appropriate action steps will be determined by 1) the problems which have been identified such as odour or medical symptoms, and 2) the results of measurements carried out in the investigation. Appendix A provides an outline, in Tables A-i to A-4, of the action steps and remedial measures which correspond to the various problems and measurements. The recommended remedial measures are the minimum measures that will reduce the formaldehyde gas concentrations (resulting from the UFFI) in the living space. The reduction in formaldehyde gas concentration achieved by the measures will vary. In some cases after the remedial measures are complete, further measurements are recommended. The services of a consulting engineer or architect with a knowledge of UFFI and building construction may be required in some instances to assist in analysing the problem and selecting the appropriate remedial measures. Where health problems exist, a full medical assessment of the occupants is advised. Decisions as to the remedial measures should take into account the range of susceptibilities of all persons in the household. For those homes where there are no serious problems related to the presence of the UFFI, minimum preventive measures are suggested to reduce the potential for serious problems occurring in the future. These are discussed in Section 4. In view of the sensitivities some persons may have to formaldehyde, persons involved in removal of UFFI should exercise proper safety precautions. The wearing of goggles, dust masks, and appropriate clothing is discussed in Section 5. There are a number of subjects related to identifying and solving UFFI problems which could not be covered in detail in this publication because development of the information is still in progress. Brief summaries have been included in Appendix B and reference made to them in the text. PAGENO="0175" 171 -3- 2.0 PROBLEM IDENTIFICATION 2.1 Medical Symptoms The health problems caused by exposure to formaldehyde gas in air include eye, nose and throat irritation, coughing, headaches, dizziness, and, in very high concentrations, bronchopneumonia and pulmonary oedema (1)~ When any of these symptoms are encountered, a doctor should be consulted to determine the cause or to advise the patient on the likelihood that the symptoms are related to the presence of UFFI. A specialist may be required to identify the possible causes of the symptoms. The doctor should be informed of the patient's history of exposure to UFFI, formaldehyde gas and other chemicals or pollutants both at home and work. Exposure to high concentrations of the gas, as evidenced by strong odours that may have occurred for a time after the installation of !JFFI, repeated physical contact with the tJFFI, especially when wet, contact with the liquid components, or breathing of formaldehyde dust particles may have initiated a sensitivity to formaldehyde. If investigations fail to find a correlation between a health problem and exposure to formaldehyde gas, but there appears to be a correlation with the environment in the house, the insulated cavities should be checked for the presence of fungi. The actual reaction of the patient to fungi will depend upon the pathological potential of the individual species and whether spores are present in the air of the living space. Although most fungi are benign, others are known to cause reactions or. disease in some people. Many fungi induce respiratory sensitization in susceptible individuals; subsequent exposures can then provoke an asthmatic attack.(2) A list of fungi that have been found to be associated with UFFI is contained in Appendix C. Further discussion of fungal growth is presented in Section 2.3. Persons who have become sensitized to formaldehyde should take precautionary steps to prevent skin contact with liquid detergents, cleaning solvents, deodorizers, concentrated fabric softeners, perfumes, skin creams or other cosmetics, or other materials which may contain formaldehyde and cause a skin reaction. Inhaled formaldehyde gas from other sources such as tobacco smoke, particle board, plywood and treated fabrics may also cause symptoms. 2.2 Formaldehyde Gas (Odour) and its Entry into the Living Space The odour of formaldehyde gas is one of a number of odours which may be emitted from a cavity containing UFFI. The odour of formaldehyde gas can be described as pungent (sometimes sweet) in high concentrations but less definitive at low concentrations. Other odours can be related to moisture. Fungal growth often produces a musty odour. The urea-formaldehyde-based resin used In producing the foam contains free formaldehyde which is said, by the~manufacturers, to be necessary for the reaction between the resirvand the~.foaming agent. Much of this free formaldehyde gas is released from the foam shortly PAGENO="0176" 172 -4- after installation. Formaldehyde gas is also liberated from the UFFI when the reaction between the resin and foaming agent is reversed causing degradation of the UFFI. The rate of degradation increases with increased humidity and/or increased temperature. The gas that is emitted nay be carried away immediately by air movement or it can be stored in the foam or other materials in the wall and then enter the house by air movement or diffusion through the wall. This degradation also decreases the effective thermal resistance of the UFFI. FIGURE 1 POTENTIAL AIR LEAKAGE PATHS IN A WOOD-FRAME HOUSE Air movement is a more efficient mechanism than diffusion for transporting the gas. Figure 1 identifies some of the common air leakage paths encountered in wood-frame houses. The rate of air flow is governed by the details of the house construction and the pressure difference across the wall cavity. The latter depends on the way the house is operated, the difference between the temperature and humidity inside and out, time of day, wind speed and direction, location of openings relative to wind direction, and furnace operation. Air may flow from the outside into the cavity, then into the living space carrying the formaldehyde gas with it. The air flow may also be in the reverse direction carrying the formaldehyde gas to the outside. Further discussion of the principles of air infiltration is contained in Section 3.1. PAGENO="0177" 173 -5- In two apparently similar houses having the same brand and batch of UFFI, installed by the same applicator, the resultant material may differ so much that one house could have a problem and the other not. Even where the rate of formaldehyde gas emission from the UFFI in both houses is the same, the gas can be carried to the outside in one case and to the inside in the other case due to the characteristics of the houses and their operation. Formaldehyde gas can collect in areas of a house where there is restricted air movement, such as under skirted sofas, and so may be difficult to remove by occasional venting of the house. Formaldehyde gas can be entrained in a moist air flow and collect near the ceiling. Formaldehyde can be absorbed by wood and adsorbed on linens, draperies, carpets, and surfaces of walls and furniture. Since the smell of formaldehyde in contaminated air will seem strongest when compared to cleaner air, its presence is usually easiest to detect when a person enters the house from outside. If detectable, the odour will be strongest where gas is entering the house from an insulated cavity. Openings around electrical boxes in exterior walls~ are common entry points. The presence of formaldehyde gas in the wall can be sensed by checking for odours around these boxes. A small hole drilled into the wall cavity, just above the floor in the first storey wall where air infiltration is expected, may also be used to check for odour. 2.3 Moisture in the Insulated Cavity The presence of moisture in an insulated cavity is undesirable for two reasons. First, moisture increases the rate of formaldehyde emission over that which would occur under dry conditions. Second, if sufficient moisture is present, fungal growth may occur either on the foau~ or the surfaces of the cavity. Spores from the fungus can be transported, in the same manner as formaldehyde gas, by the air that flows from the wall cavity into the living space. Fungal growth may also penetrate through the gypsum or lath and plaster and appear as a growth or discoloration on the painted surface. The growth of wood rot and other fungi can have a serious effect on the long-term integrity of the wood structure as well as being a potential health risk to the occupants. Moisture in an insulated cavity may come from a number of sources. Just after being installed, UFFI contains up to 75 per cent water by weight. The foam must be able to dry quickly and remain dry. Under some adverse conditions the UFFI and cavity may stay wet for several months or even years after installation. Moisture may also enter the wall as a result of rain leakage and of condensation of moisture from humid air leaking from the living space into the insulated cavities during cold weather. Both of these sources can cause either general or localized moisture build-up. 97-153 O-82---12 PAGENO="0178" 174 -6- The measurement of the moisture content of wood components is one of the tests required in the investigation. The moisture content can be determined using a moisture meter as described in Appendix B. Measurements made at test openings or at intervals along the bottom plate (or lower portion of the stud) in the wall will provide an indication of general and localized moisture levels and the potential for fungal growth. The moisture content of wood in most cases must remain over 20 per cent for more than 3 weeks to.establish the growth of wood rot varieties of fungus. Other less common types of fungi may grow at lower moisture levels. The presence of fungal growth in the foam and cavity may be observed by cutting a test opening through the interior wall finish (Appendix B). Another way to observe the condition of the material in the wal.lcavity is by using an optical probe (endoscope) (Appendix B). The mostappropriate location is where the moisture content of the bottom plate of the wall has been measured and found to be high or where there are obvious signs of fungal growth such as a growth on, or discoloration of, the surface. When observations indicate possible fungal growth, a test opening should be cut to remove material samples for analysis. Samples of the foam and surrounding organic material should be submitted for identification as described in Appendix B. The action steps for dealing, with walls ~having a high moisture content are outlined in Appendix A, Table A-l. Possible methods for drying the walls are discussed in Appendix B. If fungal growth issuspected or has been identif led, a consulting engineer or architect knowledgeable in the control of fungus should be retained to investigate, the problem and advise on remedial measures. 2.4 Visible Indications of a Problem Cases of exceptionally poorapplication can often be identified visually. If, at the time of UFFI application, there is leakage of the resin component (usually a light brown.liquid) - this indicates one or more problems. These include an incorrect ratio of the components, application of the material in unsuitable weather conditions, incompatibility of the UFFI with the other building materials, or the component chemicals (resin) used were beyond their shelf life. This information is useful in selecting measurement locations or assessing the extent and nature of remedial measures. Paint peeling or flaking on the siding or interior finish may indicate that the cavity did not'dry properly. The corrosion of electrical boxesorterminals in insulated cavities also indicates that moisture is or was present. `Some electrical boxes may have been filled with UFFI during application and not subsequently cleaned. This can encourage corrosion and overheating of the~termlnal. An electrician should check the receptacles and replace any thathave been. damaged. PAGENO="0179" 175 -7- Fungi blooming on the wall surface may indicate fungal growth in the cavity. When fungal growth is suspected, the procedures in Section 2.3 should be followed. 2.5 UFFI Locations Requiring Special Consideration The use of UFFI in locations other than empty exterior wood-frame walls, such as masonry walls, attics, ceilings and below-grade locations, has been discouraged by various authorities. The inability of the cavity to dry through to the exterior, the risk of moisture entering the cavity from rain or groundwater leakage, and higher temperatures in attics and ceilings, all contribute to the need to limit the use of UFFI. The Canadian General Standardé Board Standard for UFFI indicated its application only in exterior wall cavities. Canada Mortgage and Housing Corporation in 1977 accepted UFFI only for use in empty exterior wood-frame wall cavities. Special attention should be given where UFFI has been installed in the locations discussed below. Cathedral ceilings, flat roofs and attics UFFI installed in cathedral ceilings (Figure 2), flat roofs, and attics is exposed, often simultaneously, to high temperatures and high humidities. The foam may also be subjected to moisture from roof leaks rED RAL CElL IN FIGURE 2 UFFI INSTALLED IN CATHEDRAL CEILING and to accumulation of condensation due to leakage of moist air and diffusion of water vapour through the interior surface in winter. Under these conditions, generation and concentration of the formaldehyde gas in the cavity will increase. Air flowing downward through the ceiling PAGENO="0180" 176 -8- during the operation of a fireplace, furnace, stove and/or bathroom fan, and when particular wind conditions exist, carries the formaldehyde laden air into the living space. UFFI installed in the floor of open attics is subjected to air movement over its surface. This may result in an increase in the emission of formaldehyde due to a change in the equilibrium of free formaldehyde in the foam. The foam will liberate more formaldehyde in an attempt to re-establish equilibrium. Cracks in the UFFI can increase the rate of liberation as they allow rapid loss of formaldehyde gas. Overhangs, canopies and intermediate floors UFFI has been installed in overhangs (Figure 3), canopies and intermediate floors. With balloon frame construction this may have happened accidentally where the wall cavity is connected to open joist spaces (Figure 4). In other cases, these areas were insulated in an attempt to reduce air infiltration and eliminate cold floors. Construction details often provide numerousopenings and cracks which allow air and formaldehyde gas infiltration into the living space. Below-grade applications UFFI was considered unsuitable for installation below grade * (Figure 5), because of the prolonged exposure to high humidity, water leakage, and the absence of a good drying environment. If these conditions exist the rate of degradation of the foam would be high and result in a higher rate of~.formaldehyde emissions. Air movement at this level is normally from the outside through the insulated cavity to the living space. Almost all the formaldehyde released from the UFFI would, therefore, enter the house. Interior partitions UFFI has been used in a limited number of cases as an acoustical insulation in party walls or partitions. In such locations, the UFFI is exposed continuously to room conditions. As a result, the foam tends to be warmer than if it was in an exterior wall. Since there is little, if any, air flow to the outside and most interior partitions do not have a good air seal at the floor/wall junction, the formaldehyde gas is more likely to enter the living space. 2.6 Measurement of Formaldehyde Gas Knowledge of the formaldehyde gas concentration in the insulated cavity, and in some situations the living space, is essential to the analysis of a UFFI problem or in determining the potential for formaldehyde gas infiltration. If the UFFI must be removed, the PAGENO="0181" 2nd FLOOR OFFI r FLOOR JOIST FIGURE 3 UFFI IN FLOOR OVERHANGS ii - UFFI -SHEATHING FIGURE 4 OFFI IN JOIST SPACES IN BALLOON-FRAME CONSTROCT ION L~- FIGURE 5 OFFI IN BASENIENT WALL 2nd FLOOR 177 -.9-. 2nd FLOOR ~`UFFI RI FLOOR EXTERIOR WALL FLOOR BRICK- / 151 FLOOR PAGENO="0182" 178 - 10 - measurement of the rate at which material in contact with the IJFFI emits formaldehyde is one factor to be considered in establishing the removal procedure. This test is conducted under laboratory conditions. Insulated Cavity Gas Concentration The potential for high formaldehyde gas concentrations in the living space is best defined by measurements of the formaldehyde gas concentration in the insulated cavity. This type of measurement can be done by consultants or the homeowner. Compared with the air in the living space, the air in the insulated cavity will generally have a higher concentration of formaldehyde gas and be influenced less by external factors. If the concentrations of formaldehyde in the insulated cavities are high, then air leaking through the cavity into the living space will have a high formaldehyde gas concentration. The concentration of formaldehyde gas in the wall cavity has therefore been selected as one of the measurements on which to base a decision on the extent of remedial measures required for a particular house. Gas Concentration in the Living Space Measurements of formaldehyde gas in the living space should only be done after the necessary preparatory steps have been carried out. These steps are described in detail in Appendix B. Because of the complexity of the equipment and analysis, the measurement is conducted by consultant or laboratory personnel. The concentration of formaldehyde gas will be affected by many factors including changes in wind speed and direction, temperature, humidity and house operation. The measurement of formaldehyde gas in only the living space therefore, is generally not sufficient to establish a course of remedial action. It is useful, however, to carry out measurements of the concentration in the living space in addition to those in the wall cavities when there is a need to determine the effectiveness of the remedial measures or where there have been related health problemse The initial ratio of the formaldehyde gas concentration in the living space to the concentration in the insulated cavity is a benchmark which can be compared with measurements made after completion of remedial measures. If the UFFI has been removed, the measurement of the formaldehyde gas concentration in the living space should be compared with the ambient concentration. Ambient concentrations will vary within a city and will, generally range from below 0.01 to 0.03 ppm (parts per million). Higher ambient concentrations will exist in areas of heavy traffic.~3~ Formaldehyde Emission from Materials in Contact with UFFI A laboratory test procedure* for measuring, under a standard set of conditions, the emission of formaldehyde from cured UFFI was developed by Rybicky and Kambanis of Reichhold Chemicals.(4) *The procedure was reviewed by the Canadian General Standards Board Committee for UFFI and proposed for inclusion in the standard. Laboratories can obtain `copies of the Reichhold procedure by writing to Standards Office, Canadian General Standards `Board, Department of Supply and Services, Ottawa, Canada, K1A 1G6. - PAGENO="0183" 179 - 11 - The test can be performed by material testing laboratories. The - apparatus used in the test can also be used to assess the potential for formaldehyde emission from other materials such as gypsum board, lath and plaster, and fibre board. Such testing of materials in contact with UFFI is necessary when the UFFI is going to be removed. The results identify the extent to which resin-laden water from the IJFFI was absorbed by other materials. This is an important factor when the foam was not properly installed and resin-laden water was released. When in contact with water or high- humidity air, the resin-soaked materials could become. a significant source of formaldehyde gas. In some cases when UFFI must be removed from the cavities, and where the gypsum board or lath and plaster has been shown to have a high formaldehyde gas generation capability, the foam should be removed from the interior and the gypsum board or lath and plaster replaced. 2.7 Summary - Problem Identification The preceding provides information necessary to investigate a problem related to UFFI. The completed investigation should yield the following information: i) The nature of the problem - health - odour - moisture - not identifiable 2) Moisture content of wood in cavity 3) Formaldehyde gas concentration in the insulated cavity and possibly the living space 4) Which cavities were insulated with UFFI. With this information a decision must be made regarding the remedial measures to be taken to reduce the severity or cause of the problem. There are a number of options available; these are discussed in terms of Action Steps and Remedial Measures in Appendix A. These steps are categorized by the type of problem and broken down into "classes" based on the test results. The classes are determined using the relationship. between formaldehyde gas concentration in the wall cavities, temperature, and relative humidity (Figure A-l). The action steps represent the minimum remedial measures that should be considered and should not be regarded as the only way to approach a problem relating to UFFI insulation. An understanding of the options is required before decisions can be made regarding the remedial measures. These remedial measures are discussed in Section 3. PAGENO="0184" 180 - 12 - 3.0 REMEDIAL MEASURES Procedures for reducing formaldehyde gas concentrations in homes have only recently been established and their application to a wide variety of houses is limited. The properties of the !.JFFI in a particular house, the sensitivity of the occupants, and the building characteristics will all affect either the type and severity of, or potential for, problems. No two houses, occupants or UFFI installations are likely to be the same and thus the success of remedial measures will vary. Only guidelines to the selection of the appropriate remedial measures can be provided. The interpretation of the guidelines by a consulting engineer or architect may be required. 3.1 Principles of Remedial Measures Air Infiltration Air infiltrates through openings in a house when and where the outside air pressure is higher than the interior air pressure. (This is called negative pressure difference.) It is impossible to eliminate all air infiltration even when a conscious effort is made to seal holes in exterior walls. The effects of wind, temperature, chimneys and, in winter, stack action* on the pressure across a wall are illustrated in Figure 6. As shown, one section of the exterior wall can be under a positive pressure difference and another section can be under a negative pressure difference at the same instant. Positive pressure differences (interior air pressure higher than that outside) -cause air to flow from inside to the outside carrying formaldehyde gas, and fungus spores if present, into the atmosphere. Negative pressure differences result in an inward flow of air. The negative pressure differences should be reduced to minimize infiltration of formaldehyde laden air. Air pressure differences in the living space, however, should not be increased to the point where there is excessive flow of moist indoor air into the wall as this could cause serious condensation problems in cold weather. If a house is pressurized to reduce the negative pressure difference, the humidity level in the living space should be kept as low as possible without causing discomfort to the occupants. This will further reduce the possibility of damage caused by condensation in the cavity. As many openings as possible through which air can leak into the wall or roof space should be sealed to reduce the possibility of condensation accumulation. Formaldehyde Gas Concentration UFFI and materials that have come in contact with the wet foam release formaldehyde gas. Any flow of air from the insulated cavities to the living space will carry the formaldehyde gas increasing the concentration in the living space. There is also a small indeterminate amount of formaldehyde gas that diffuses from the insulated cavity through the wall materials to the living space. The lath, plaster, *pressure differences caused by the warm moist air expanding and rising. PAGENO="0185" I STACK EFFECT (WINTER) ¶ ¶~ ¶ ¶ CHIMNEY AND EXHAUST FANS OPERATING -0 ~~~Tttt~ WIND STACK EFFECT + WIND + CHIMNEY AND (WINTER) EXHAUST FANS OPERATING FIGURE 6 SIMPLIFIED PRESSURE DIAGRAMS FOR HOUSES 181 - 13 - WIND WIND WIND PAGENO="0186" 182 - 14 - gypsum board or sheathing that is between the insulated cavity and the living space have pin holes, cracks and joints that are open to the air space so they can only provide a limited resistance to air flow. The concentration of formaldehyde gas In the livingspace is also affected by the concentration of formaldehyde in the outside.air, the rate of emission of formaldehyde from indoor furniture or furnishings, and other activities that produce formaldehyde such as frying and smoking. The concentration of formaldehyde in the air in a house can be estimated using simplified equations from a knowledge of the formaldehyde gas concentration in the insulated cavity and an estimate of the air leakage characteristics. Consider the effect of the concentration of formaldehyde gas in the outside air. If it is constant at all times of the day and if there are no other sources of formaldehyde, the concentration of formaldehyde gas in the living space air would rise to that of the outside. In actual conditions, the contributions from outside would be a constant that is added to all the other contributing factors. For simplicity, then, it is possible to limit the discussion to the contribution made by the UFFI to the living space concentration of formaldehyde gas. On average, the amount of air that flows into a room must equal the amount that flows out (Figure 7). Let n equal the amount of air that flows into a room through cavities containing UFFI and m equal the amount of air flowing into the room through other openings. The rate at which air must leave the room is therefore m + n. Assume that the average concentration of formaldehyde gas in the insulated cavities is Cc and that from all other sources is zero. Then the amount of formaldehyde gas entering the living space per unit of time is n x Cc Let the concentration of formaldehyde gas in the livil)g space be defined as C; the amount .of formaldehyde leaving the living space is then (m + n) x C. When the concentration of formaldehyde gas in the cavity and the air flows are constant, n x Cc = (m + n) x C or C = (n/(m + n)) Cc The amount of air flowing through the insulated cavity, n, is usually much smaller than that from all other sources so that approximately, C(n/m)x Cc That is,~ the concentration of the formaldehyde gas in the living space is reduced from that in the cavity by the ratio of the rate of flow of air through the cavity to the rate of flow of air from allother sources. PAGENO="0187" 183 - 15- r THROUGH UF~i>r LIVING LEAVING ROOM. CAVITIES. n THROUGH_OTHER~ SPACE Im + F~INGS.. m AIR FLOW IN AIR FLOW OUT OURCES J FORMALDEHYDE M UFFI AM~ENT : ~~EHYDE ~ FORMALDEHYDE FORMALDEHYDE SOURCES FIGURE 7 FLOWS OF FORMALDEHYDE GAS THROUGI~ A LIVING SPACE Based on limited NRC data, the following are the approximations for n/n: - for air flowing inward through the walls of modern houses that have gypst~ board finish with foam only in the walls, n/rn is 1/15 to 1120 AIR FLOW AND FORMALDEHYDE BALANCE - for houses built with lath and plaster, n/rn is 1/25 to 1/35 PAGENO="0188" 184 - 16 - The units of measurement for formaldehyde gas are commonly parts per million (ppm) or milligrams per cubic metre (mg/tn3 ). The unit parts per million will be used in the discussions since this is the unit read by the instruments for measuring wall cavity concentrations. The relationship (5) between those units is, I ppm = 1.248 mg/tn3. Example If n/tn = 1/15, there are no other sources of formaldehyde gas, and the formaldehyde gas concentration in the wall cavity is 1.5 ppm. Then the contribution to the living space concentration of formaldehyde gas by the UFFI foam would be 11.15 x 1.5 0.1 ppm The foregoit~g simplified method can be used to identify measures to reduce the concentration of formaldehyde gas in the living space. These measures are: 1) increase m, the flow of outside air directly into the house. If m was doubled, C would be reduced by one half. This could be accomplished by selective window openings or by blowing outside air into the living space with.a fan. 2) decrease Cc~ the concentration of formaldehyde gas in the insulated cavity. If Cc was reduced by half, C would also be similarly reduced. This could be accomplished, for example, if the UFFI was wet and the cavity was subsequently dried. 3) decrease n, the flow of air through the insulated cavity. If n was reduced by half, C would be also. This could be accomplished by sealing the openings from the cavity to the inside and by decreasing the negative pressure difference across the wall, which is the force causing the air infiltration. 4) the overall concentration in the living space can be reduced by circulating the air in the living space through special filters. It should be remembered that we have assumed outside formaldehyde gas concentrations and formaldehyde gas from other indoor sources to be zero. The contribution from outside could only be reduced by using special filters. The indoor sources can be reduced by either ventilation or special filters. Although the remedial measures discussed in the following generally apply to UFFI installed in wood stud walls, they can, with some care, be applied to UFFI installed in other locations such as flat roofs, cathedral ceilings and to masonry construction. Each situation will, however, have its own peculiarities which must be considered. PAGENO="0189" 185 Remedial measures aimed at reducing the amount of formaldehyde gas entering the living space are most effective when combined. Sealing reduces the formaldehyde concentration in the living space and slightly reduces the air change rate while other measures will increase the air change rate. Figure 8 is a graphical illustration of the accumulated effects of sealing the exterior wall, and ventilation and pressurization of the living space. Although simple ventilation dilutes the formaldehyde gas, it is often not adequate to bring the concentrations down to near-ambient concentrations without excessively high air change rates. A combination of sealing and pressurizing to reduce the negative pressure difference may be the most effective method of reducing the concentration of formaldehyde gas in the living space. The type of a C.-, C., z > z 0 z C-) z 0 C-) = a 0 - 17 - 0. 13 0. 12 0. 11 0.10 0.09 0.08 0.07 0.06 0.05 0.04 0.03 0.02 0.01 3.0 ADDITIONAL VENTILATION, air changes/h 4.0 FIGURE 8 ACCUMULATED EFFECTS OF REMEDIAL MEASURES ON FORMALDEHYDE GAS CONCENTRATION IN LIVING SPACE PAGENO="0190" 186 - 18 - construction will have a bearing on which remedial measure is emphasized. For example, balloon frame construction is very difficult to seal adequately because of the floor-joist wall-stud junction. One would seal those areas which would be effective but put more emphasis on the forced ventilation measure to reduce the air infiltration. The development of new or more effective techniques may be required to meet the unique characteristics of a particular house or construction type. Appendix ID provides a summary of the basic types of Canadian house construction. Interim Measures In cases where occupants of a house are particularly susceptible to the presence of UFFI, some of the less expensive remedial measures may be necessary as interim measures until a proper long-term course of action is decided upon. Taping of baseboards, fans and increased air change rates are effective means of temporarily reducing formaldehyde concentrations. The contribution to the formaldehyde gas concentration in the living space from other internal sources will also be reduced by additional air changes. 3.2 Sealing the Inside Surface of the Exterior Walls Regardless of other remedial measures taken, the gypsum board or lath and plaster on the exterior wall should be sealed to prevent infiltration of formaldehyde-laden air. All holes, cracks or gaps in the wall finish must be repaired.* In cases where the UFFI is to be removed, sealing of inside surfaces is still necessary to reduce the possibility of residual formaldehyde gas entering the living space. It may, however, be done after the UFFI is removed, depending on the procedure used. Electrical Outlets Electrical outlets are a common source of air leakage and should be sealed by applying a gasket between the cover plate and the wall. Inexpensive gaskets are available at hardware or building supply stores. Gaskets that are CSA approved and acceptable to the local electrical authority should be used. The local electrical authority should be contacted to determine if regulations require that the gaskets be installed by an electrician. Wall/f loor junction The junction between the interior wall finish and the floor should be sealed against air infiltration. Acoustical sealant is commonly used for this purpose (Figure 9). Other techniques to produce a seal can also be effective. The use of weatherstripping or special foam-backed tapes available at hardware stores is illustrated in Figures 10 and 11. * mylar, foil, or vinyl wallpaper provides an air leakage and diffusion barrier. PAGENO="0191" 187 FIGURE 9 SEALING WALLIFLOOR JUNCTION WITH SEALANT ~~BASEBOARD FLEXI BLE WEATHERSTRIPPING - FINISH FLOOR ~- ~ ~ SUB FLOOR ~UFFI OFF I - 19 - FINISH FLOOR S OR FL OAR UFFI UPPI / ~ / OFFI - GY PS AM GYPSUM BASEBOARD PIPE WRAP FLOOR _________________ FLOOR \ OFF I FIGURE 10 SEALING WALL FLOOR JUNCTION WITH PIPE WRAP FIGURE 11 SEALING WALLIPLOOR JUNCTION INITH FLEXIBLE WEATHERSTRIPPING PAGENO="0192" 188 - 20 - In cases where board subfloor was used, sealing between the boards will be required to reduce movement of air into the floor space and back into the living space at some other location. If odours from sealants cause discomfort to, or a reaction in, occupants sensitive to the formaldehyde gas, the sealants should be covered by aluminum tape or another technique that produces less odour should be used. Some imagination combined with a trip to the local hardware store may result in a neat, effective method to seal a particular wall to the floor. The joints around window and door frames should be sealed where there are openings between the rough opening and the frame. In two-storey houses, air leakage paths connect the wall cavities to the space between the first and second floor. Such paths may require special consideration. The flooring and/or gypsum board ceiling may have to be removed to gain access to these locations. This may be impract~ical. Infiltration is therefore best reduced by reducing the negative pressure difference across the wall as discussed in Sections 3.3 and 3.4. Wall surfaces Wall surfaces must be sound, free of pin holes and cracks, and covered with good quality paint or wall paper to prevent air leakage and reduce the diffusion of formaldehyde gas through the material. If the gypsum board or lath and plaster has been cracked due to the pressures developed during installation of UFFI, these cracks should be repaired before repainting or wall papering. If a bulge that is cosmetically undesirable has been produced by the UFFI installation, the interior - wall finish should be removed. The UFFI can then be removed following the procedures described in Section 3.6. Where UFFI was installed in a wall finished with paneling and where the wall does not have a polyethylene air/vapour barrier or the joints between panels are not sealed, the joints should be sealed. This type of paneling can often be readily removed and reapplied, facilitating the removal ~f the UFFI. Paneling suspected of beir~g an additional source of formaldehyde gas should be checked for emissions before reinstallation. Interior Partitions Until very recently, there was no attempt during house construction to provide an air barrier at the junction of interior partition walls and exterior walls. Cold drafts at the floor line or from the electrical outlets in the partition wall are good indicators of paths of air infiltration. These locations should be sealed especially where the formaldehyde gas concentrations in walls are high. Negative pressure differences that encourage infiltration should be decreased as described in Sections 3.3 and 3.4. PAGENO="0193" 189 - 21- 3.3 Increasing Ventilation by Use of Forced Air Furnace Fan or Windows One simple way to. reduce the negative pressure difference across a wall is to install a fresh air intake on the cold air return duct of a forced air furnace (Figure 12). A furnace maintenance company should be contacted regarding installation. The intake must draw air from the windward (prevailing wind) side of the house. The furnace circulation fan, preferably two speed, should be set to run continuously at low speed. This will provide a controlled rate of air supply and a reasonable distribution. The duct should be approximately 100 mm to 150 mm itt diameter, contain a one-way damper and be insulated to minimize condensation on the pipe. If the pressure in the house is excessive, the damper should be adjusted to reduce the inward flow of air. The furnace fan speed could also be slightly lowered to reduce noise when the fan motor operates at a single speed. This adjustment should be made by a furnace service person who should also check the operating temperature of the furnace. The pressure difference across the wall at the first floor level can be checked with special sensitive differential pressure indicators. Operation of kitchen or bathroom fans, clothes dryer, or other exhaust-type fan will probably increase the rate of infiltration by increasing the negative pressure difference across the wall. Operation of these exhaust fans should be reduced to a minimum or modifications made to the system. FIGURE 12 97-153 0-82---13 PAGENO="0194" 190 - 22- Window ventilation may be effective for removing formaldehyde from the living space when the windows can be left open for extended periods of time. The flow of fresh air from windows, however, is not well controlled. In winter, since cold drafts will result, It is most likely that the windows would be closed before adequate ventilation is achieved. If windows are being used for ventilation they should be opened so that there is greater open area on the windward side(s) of the house than the sum of openings on the leeward and other sides. The amount of negative pressure difference that usually exists across the main floor walls will be decreased if a basement window, on the windward side of the house, is left open. The wind in this case would act like a fan blowing into the basement. Problems with drafts, pooling of cold air, lack of security and the possibility of rodent entry may have to be considered if windows are used as a source of ventilation or to reduce negative pressure differences. Fireplaces should be sealed when not in use to reduce the depressurization of the house caused by airflow up the chimney. Most fireplace dampers do not provide such a seal. A sheet of plywood cut large enough to cover the opening can be edged with suitable weather- stripping and anchored to the adjoining wall or masonry. Installation of a dampered duct from outside the house to the vicinity of the fireplace grate will act as a combustion air intake and will reduce the depressurization otherwise caused by the flow of air from the living space up the chimney. This can also be accomplished by opening a window a small amount during operation of the fireplace. 3.4 Forced Ventilation Houses do not always have a forced air heating system and the ventilation provided by a fresh air intake on the furnace is not always adequate. In these cases, a separate forced air ventilation system should be installed. The forced air ventilation system utilizes a fan to supply outdoor air to the living space. This fan may be installed in conjunction with an air to air heat exchanger as described below. The addition of the heat exchanger allows increases in the air change rate well above that which could be provided by one fan or which would be economical using two fans. A ventilation system will reduce the negative pressure difference across the exterior wall and will decrease the air infiltration. Flows should be adjusted so that the pressure difference is close to zero at the ground floor level when the furnace is not running. The fresh air supply from the fan or heat exchanger should be connected to a distribution system; to the forced air heating system when there is one. A small distribution system using small ducts should otherwise be considered. PAGENO="0195" 191 23_ Fans Forced ventilation can be provided with a good quality centrifugal or squirrel cage fan that operates with a low noise level. The fan can be installed in a basement window so as to draw air from outside and discharge it into the basement. An electric heater can be installed after the fan's discharge to reduce cold drafts and reduce the possibility of pipes freezing. The cost of the fan system should be less than $500, but for houses that cannot be adequately sealed the cost to heat the air would be high. When fan inlets are located in areas accessible to children, protective covers should be installed to prevent accidents. Heat Exchangers Heat exchangers have become common in low energy houses where the air leakage has been reduced to the point that a supply of fresh air is required to maintain air quality. Heat exchangers can be obtained with a pair of adjustable speed fans, one on the intake and the other on the discharge. These fans force air through the heat exchanger in opposite directions. Heat is transferred from the room air through a conductive membrane to the cold fresh air flowing in the opposite direction. The efficiency of heat recovery is highest where the two flow rates are equal but this will occur only in very tight houses or in very special circumstances. When a heat exchanger is installed in houses containing UFFI, the volume of supply air should be greater than that of the exhaust air to reduce the negative pressure differences across the exterior walls. The conductive membrane in the heat exchanger must operate with a pressure difference across it. The manufacturers should be consulted prior to purchase to confirm the suitability of their product to this type of application. The prices for heat exchangers in 1981 run from approximately $400 to $1000. Less expensive portable models are now available for individual room ventilation. 3.5 Air Filter System Filtering systems are available which remove formaldehyde gas from air. The formaldehyde-laden air is circulated through a series of filters, one of which is a granular chemisorbent bed. The formaldehyde gas is first adsorbed by the chernisorbent granules. A chemical then reacts with the adsorbed gas in an irreyersible chemical reaction. The filter system also removes from the air a number of other pollutants and other components of UFFI gas to which a person already sensitized by the formaldehyde gas might react. The filter medium has a limited life because the chemical is depleted as it reacts with the pollutants. Carbon monoxide and carbon dioxide are not removed from the air so must be exhausted to the outside, necessitating a supply of fresh air to the living space. PAGENO="0196" 192 - 24- The filter system can be installed in a permanent position or mounted on casters and moved about the house as required. The output from the filter can be ducted to an air distribution system to ensure that filtered air reaches all parts of the house. Doors between rooms should be left open to allow the air to circulate. The distribution of the filtered air can be assisted by using portable circulating fans when the unit is located on the main floor and not connected to a distribution system or when a portable unit is used. Filter systems range in price (in 1981) from $1000 to over $3000. The size of unit required depends on the sensitivity of the occupants, the concentration of pollutants and the size of house. The house should be sealed as discussed in Section 3.2 to reduce infiltration of formaldehyde-laden air which would decrease the life of the filter medium. The manufacturer of the filter should advise the potential purchaser what byproducts will be emitted from the filter and what particles may be in the air discharged from the filter. In cases of medical problems this information should be passed on to a doctor for comment or to enable tests for sensitivity to the chemicals. CAUTION: Persons previously exposed to formaldehyde may be sensitive to small amounts of particulate matter or new products being emitted *by the filter. Filter units should be equipped with high efficiency after filters to reduce this possibility. In some cases, an activated carbon filter downstream from the chemisorbent medium is sufficient to reduce to a tolerable level many trace particles or chemicals from the chemisorbent medium. Anyone experiencing a reaction following installation of the filter should immediately discontinue use of the filter and contact a doctor and the manufacturer. PAGENO="0197" 193 - 25 - 3.6 Removal of UFFI from Wall Cavities The removal of UFFI from an insulated cavity involves a series of steps which may differ slightly from house to house. The steps will include: - establishing initial formaldehyde gas concentrations in the cavity and living space - determining if removal is to be from the inside or outside - protecting or removing belongings - opening the cavity surface to gain access to the UFFI - removing the UFFI - treating the cavity - rebuilding the wall to provide thermal insulation, and an effective air seal and vapour barrier - cleaning the interior of the house - rechecking the formaldehyde gas concentration in the living space. S - carrying out further remedial measures if required. Throughout the process, proper protective clothing and equipment must be used by the workers to avoid unnecessary contact with the UFFI. The assistance of an experienced contractor or supervision of a consultant is recommended during the removal of the UFFI. Although UFFI can sometimes be removed through small holes in one of the wall surfaces, this is not recommended at present because of the difficulty in chemically treating the surfaces of the cavity following removal of the insulation. Access to the UFFI can be gained either by removing the interior finish or the exterior cladding and sheathing. The choice will depend on the construction of the house, relative costs, time of year, location of the foam, and amount of formaldehyde ~ontained in the gypsum board or lath and plaster. Removal of UFFI from accessible attics and interior partitions should be considered by the homeowner. Removal of UFFI, regardless of which side of the cavity is opened, must be accompanied by chemical treatment of any wood and fibreboard remaining in the cavity. Chemical Treatment Following UFFI Removal A 3 per cent solution by weight of sodium bisulfite (Na HSO3) should be applied onto the wood in the cavity with a new or very clean fog or airless sprayer, ~sponge, or mop. The solution is prepared using a ratio of 100 grams of sodium bisulfite in 3.5 litres of water (1 pound in 3.5 imperial (4 U.S.) gallons of water). Spraying should continue in each cavity until slight running of the liquid occurs. This should provide sufficient solution to soak the surface layers~of the materials being treated. PAGENO="0198" 194 - 26 - If the sodium bisulfite is not available, sodium sulfite can be used in the same concentration. Sodium bisulfite solutions will emit an odour of sulfur dioxide during application and drying. Some people may find the odour unpleasant but with ventilation the actual exposure should be slight (6). Sodium bisulfite is available from chemical supply outlets which are listed in the yellow pages of the telephone book. Local pharmacies may be willing to assist homeowners by ordering the chemicals and preparing the solution. As a safety precaution, it is: recommended that the chemical supplier or pharmacy prepare the solution for the homeowner. WARNING SOME HOMEOWNERS HAVE MISTAKENLY PURCHASED SODIUM BISULFATE OR SODIUM SULFATE FOR THIS TREATMENT. THESE CHEMICALS ARE MORE HAZARDOUS AND UNSUITABLE FOR THIS USE. OTHER HOMEOWNERS HAVE USED SODIUM META BISULFITE AND LOW IMPURITY COMMERCIAL GRADES OF SODIUM BISULFITE WHICH EMIT GREATER AMOUNTS OF SULFU-R DIOXIDE WHEN MIXED WITH WATER. THIS GAS HAS AN UNPLEASANT ODOUR OFTEN REFERRED TO AS A "ROTTEN FISH ODOUR'. PROPER PROTECTIVE EQUIPMENT AS OUTLINED IN SECTION 5.0 IS ESSENTIAL TO THE SAFE HANDLING AND THE USE OF THE CONCENTRATED CHEMICALS ANT) SOLUTIONS. Other chemicals for treating the cavity have been tried with limited success. Ammonia gas is difficult to handle and requires several applications. Ammonia solutions are less effective than ammonia gas. In houses where a serious health problem or sensitization has occurred, the cavity should be dried, covered with a temporary cover such as polyethylene, and left for a minimum of one day or more preferably one week. The formaldehyde gas concentration in the air of the cavity and the living space should then be remeasured. The procedure used for measuring the air in the living space will be required for measuring the concentration in the cavity since the concentration will be below the range of the hand pump detectors. The concentration in the cavity should be near ambient. If the concentration in the living space is still high, a comprehensive investigation should be made to locate UFFI which may have been overlooked or other sources of formaldehyde gas. If the concentration is high in the wall cavities, a second application of sodium bisulfite solution should be made to the cavity, the cavity dried, re-covered and tested again. The procedure of opening the cavity, removing the UFFI, treating the wood, improving the air barrier, reinsulating and closing the cavity differs depending on whether it is done from the inside or the outside. To emphasize the key points each procedure will be discussed separately. PAGENO="0199" 195 - 27 - Removal of UFFI from the interior There are a number of advantages to removing UFFI from the inside. Often, but not always, fewer layers of material cover the inside surface. The building structure stays protected from the environment. The inside sheathing, which often contains absorbed formaldehyde, is replaced. The exterior sheathing, whether wood or fibreboard, can be treated with the sodium bisulfite solution. An air barrier can be installed over the new insulation on the inside surface of the cavity to provide an improved air seal between the cavity and the living space. The procedure for removing UFFI from the inside should include t~he following steps: - cover or remove all furniture, carpets, draperies and food. Removal of UFFI from the interior will create a significant amount of airborne dust and UFFI particles. Unnecessary contamination of household items should be avoided. - remove all gypsum board or lath and plaster, UFFI and any other material in the cavity such as batt insulation. This material should be discarded and not reused. Scrap material can be placed in large rubbish containers of the type used by contractors. These containers are dropped off by the rental company and picked up when full or when the job is finished. A cover for the container is required to prevent the UFFI from blowing out during windy weather. - check floor spaces, ceilings, and interior partitions Ensure that all UFFI is removed. The UFFI may have been put in these locations accidentally because of the way in which the house was built. - brush, vacuum and inspect the cavity The cavity surfaces should be brushed and vacuumed to remove all residual foam. The wood should be checked for evidence of fungal growth. If fungus is present a consulting engineer or architect should be retained as discussed in Section 2.3. The consultant should select the proper measures and determine what wood should be replaced to re-establish the integrity of the structure and prevent further fungal growth. In cases where the occupants are experiencing severe chemical sensitivity, any fungicides to be used should first be checked with a doctor. Electrical wiring and receptacle boxes should be checked for any degradation caused by the installation of the UFFI. Such degradation nay be in the form of mechanical damage to or corrosion of wires, boxes, connectors or other components. PAGENO="0200" 196 28 - treat all wood surfaces in the cavity All wood, including sheathing, should be treated with the 3 per cent sodium bisulfite solution using the procedure described at the beginning of this section. If the removal is taking place in winter or cold weather the temperature of the living space should be elevated to 23°C and the house ventilated to accelerate drying. - insulate the cavity and install an air/vapour barrier Once dry, the cavity should be re-insulated with batt type insulation and a 6 nil polyethylene air/vapour barrier installed. The polyethylene should be sealed to the top and bottom wall plates and to the end studs with a durable. non-hardening sealant and staples. Where possible the polyethylene should be continuous behind interior partitions that are framed into the exterior wall. Joints between the polyethylene sheets should be located over a stud and sealed with the same sealant. Electrical outlets should be wrapped or enclosed in airtight plastic boxes to provide an effective air seal. Gaskets installed behind the cover plate can also be used. - install interior finish The choice of interior finish should be made carefully to avoid products which emit formaldehyde. In cases where there is no severe chemical sensitivity, gypsum board is the most appropriate. In cases of severe chemical sensitivity, the installation of a lath and plaster interior finish may be required to further avoid contribution of chemicals, from the finish, to the air of the living space. The interior finish can be sealed to the floor to act as a second line of defence against air infiltration. (ii) Removal of UFFI from the exterior Removal of the UFFI from the exterior also has several advantages. The process is less disruptive to the occupants and normal household activities. Sometimes fewer layers of materials are required to be removed or a structural layer prevents removal from the inside. Less protection of belongings is needed and interior redecorating is not required. The procedure for removal from the outside should include the following steps: - pressurize living space In some cases, removal of the UFFI from the exterior has resulted in a fine UFFI dust deposit on all interior surfaces. The same air leakage paths which brought formaldehyde gas into the living space, can allow air containing small particles of UFFI to enter the living space PAGENO="0201" 197 - 29 - during removal. Pressurization will reduce the infiltration of particulate matter. Fans temporarily placed in windows or doors will provide adequate pressurization during the removal process. Another way to reduce the amount of UFFI dust entering the living space is to seal the inside surface of the walls, as discussed in Section 3.2, before the removal of the UFFI. The sealing of the inside surface at some point is necessary so the money is not wasted. This may be done in conjunction with temporary pressurization during the removal process. - remove exterior cladding, sheathing, UFFI and any other material such as batt insulation Any exterior cladding that has not been in contact with the UFFI can be reused if desired. Where UFFI was placed between brick veneer and the exterior sheathing, the bricks will he impregnated with resin but could be reused if a properly ventilated air space is provided between the brick and the sheathing paper. A set of weep holes at the bottom of the wall and vent holes at the top should provide adequate ventilation. In cases of severe chemical sensitivity, replacement of the contaminated bricks should be considered. Sheathing in contact with the UFFI should be discarded. Other material in the cavity such as batts should be discarded since they will probably be contaminated. Scrap material can be placed in large rubbish containers of the type used by contractors. A cover for the container is required to prevent the UFFI from blowing out during windy weather. - check floor spaces, ceilings and interior partitions Ensure all UFFI is removed. The UFFI may have been put in these locatiohs accidentally because of the way in which the house was built. - brush, vacuum and inspect the cavity The cavity surfaces should be brushed and vacuumed to remove all residual foam. The wood should be checked for evidence of fungal growth. If fungus is present a consulting engineer or architect should be retained as discussed in Section 2.3. A consultant should select the proper measures and determine what wood should be replaced to re-establish the integrity of the structure and prevent further fungal growth. In cases of severe chemical sensitivity, any fungicide to be used should first be checked with a doctor. Electrical wiring and receptacle boxes should be checked for any degradation caused by the installation of the UFFI. Such degradation might be in the form of mechanical damage to or corrosion of wires, boxes, connectors or other components. PAGENO="0202" 198 - 30 - - treat all wood surfaces in the cavity All wood should be treated with the 3 per cent sodium bisulfite solution using the procedure described at the beginning of this Section. If removal is taking place in winter, shelters may be required to maintain temperatures high enough for drying. Interior gypsum board or lath and plaster should not be treated with the solution. A limited amount of wetting of wood lath, however, should not damage the plaster finish. - improve the air barrier and re-insulate the cavi~y~ An attempt should be made before re-insulating to improve the air seal at the interior surface of the wall. The joints between the wall plate, subflooring, and header joist should be sealed. If this is not possible from the exterior it should be done from the interior as described in Section 3.2. Joints where interior partitions frame into the exterior wall should be sealed. Electrical outlets can be wrapped or enclosed as discussed in removal from the inside. Since construction details vary considerably, careful study and consideration may be required to seal the wall. High solvent compounds should not be sprayed into the cavity to act as an air seal since they may introduce new or unwanted chemicals to the living space. Batt type insulation should be used to re- insulate. - install new sheathing, sheathing paper and exterior claddipg~ Provincial building codes, which identify minimum requirements for sheathing and exterior cladding, must be followed. The municipal building inspector can be contacted for this information. Although sheathing paper is not always required in the code, at least one layer, applied horizontally and lapped 100 mm, is a recommended practice. 3.7 Removing Residual Formaldehyde from Living Space In cases where medical problems were involved the final step in the series of remedial measures is cleaning the living space. This would include the following: - wash clothes and linens Almost all the formaldehyde which may have been adsorbed (due to the UFFI) will be removed by the washing. - clean carpets and upholstered furniture A commercial hot water carpet cleaner should be used. If this is not possible, carpets and upholstered furniture should be PAGENO="0203" 199 - 31 - cleaned by a professional cleaner. Foam from covered cushions should be aired outside. - wash walls Use soap and water and rinse with clear water. This will remove most of the formaldehyde clinging to the surface. - wash cupboards and other enclosed spaces Use soap and water if strong odours are present. [f there are no odours, simply wipe and air. - vacuum furnace air ducts and replace furnace filters This will remove dust or UFFI particles if the furnace was operating during removal of the UFFI. 3.8 SUMMARY - Remedial Measures As can be appreciated from the discussion of remedial measures, there are a number of factors to be understood for each measure. Some measures will be more suited for certain construction types or individual house features. The remedial measures are most effective when combined. With the intent of the different measures explained, and with the data obtained in the problem investigation stage, a series of minimum action steps can be selected with the aid of Appendix A. If there is any doubt about the seriousness of a situation, additional measures beyond the minimum recommended should be taken. In some cases interim measures should be undertaken pending the completion of measurements or selection and completion of the remedial measures. These measures are als6 discussed in Section 4 and Appendix A. In certain cases, the formaldehyde gas concentration in the house should be rechecked two or three days after the remedial measures have been completed. When the UFFI is left in the cavity, the formaldehyde gas concentration in the cavity should also be checked. The ratio of formaldehyde gas concentration in the living space to the cavi~y concentration can be compared with the original tests to provide an indication of the success of the measures. In cases where the UFFI is removed, the final concentration in the living space should be comparable to the ambient concentration taken at the same time. If concentrations are not near ambient (in most cases below 0.01 to 0.02 ppm), further measures should be considered. PAGENO="0204" 200 - 32 - 4.0 PREVENTIVE MEASURES In the majority of homes with UFFI there will be adequate separation between the UFFI and the living space to keep formaldehyde concentrations low in most weather conditions. Experience with the more recent formulations of UFFI is limited to a few short-term observations so there is no certainty that changes will not occur. The potential for formaldehyde gas exposure can be determined by measuring the formaldehyde gas concentration in the cavities and the moisture content of the wood in. the wall cavity. Occupants should take steps to reduce the possibility of exposure to elevated concentrations of formaldehyde gas. Table A2 provides a general guide to the minimum preventive measures which should be considered. These preventive measures, are discussed in Section 3. The minim~.mi measure that should be taken is the sealing of cracks, holes, joints or other openings in the interior surface of the exterior wall through which air containing formaldehyde may leak Into the living space. This is discussed in detail in Section 3.2. Where the foam has been installed in an accessible attic, the insulation should be removed. If the attic is inaccessible, the ceiling should at least be carefully sealed. This may require the application of a sealed polyethylene air/vapour barrier and a new finish if the existing finish is not satisfactory. The space may be vented to the outside possibly with a thermostatically controlled exhaust fan installed for operation in warm weather only. . Power fans should not be put into cathedral ceilings or flat roofs unless cross ventilation allows the air to. reach the fan. UFFI installed in internal partitions should be sealed or removed. 5.0 PROTECTIVE MEASURES FOR WORKERS The risk to persons working with the foam or other materials that have been in contact with it can be reduced by taking a few precautions: - persons sensitive or allergic to formaldehyde gas or other toxic materials should not participate in this work. - wear rubber gloves, eye goggles, suitable dust mask, long- sleeve shirt and full-length pants when handling the UFFI, material in contact with the UFFI or liquid from it. - wear rubber gloves, eye goggles, a suitable mask designed for filtering toxic gases and dusts, a long-sleeve shirt and full-length pants when mixing, handling or applying the sodium bisulfite solution. - ventilate the house when removing UFFI and when spraying the sodium bisulfite solution. PAGENO="0205" 201 - 33 - - anyworkers encountering physical discomfort, rashes or other unexplained medical symptoms should discontinue work on UFFI removal immediately. - any worker inhaling the concentrated sodium bisulfite powder should consult a doctor or a poison control centre immediately to determine the type of treatment necessary. If there are any questions regarding safety equipment, local stores selling safety equipment or provincial labour departments should be consulted. Contractors should contact the provincial Workmen's Compensation Board prior to starting work to ensure safety precautions to be taken are satisfactory to the Board. 6.0 CONCLUSIONS The measures and tests described in this Building Practice Note are intended to help homeowners, contractors and UFFI manufacturers determine if a problem exists and how it might be solved. It is advisable to keep a photographic record of visible problems and remedial measures and record observations during remedial work for future reference. With the preceding knowledge, it is suggested that a problem be addressed as follows: (1) Measure formaldehyde gas concentration in the wall cavities, and living space when appropriate, and the moisture content of wood in the wall cavity (2) Consult Appendix A for assistance in selection of remedial measures (3) Refer to Section 3 of this paper for details on remedial measures presented in this Note (4) Conduct remedial measures (5) After completion of the remedial measures, measure the formaldehyde gas concentration in the wall cavities and living space if UFFI was left in the cavity. Compare the ratio of the living space concentration to the wall cavity concentration before and after remedial measures. If the UFFI was removed the formaldehyde gas concentration in the air of the living space should be comparable to ambient concentrations (6) Perform additional remedial measures where necessary The remedial measures discussed are based on sound building science principles and the current knowledge of UFFI. Their application to the wide variety of houses experiencing problems is limited. The PAGENO="0206" 202 - 34 - authors welcome reports on the application of the remedial measures, particularly on any difficulties that were encountered, and on the effectiveness in overcoming any problems. REFERENCES 1. National Health and Welfare Canada, Final Report of the Department of National Health and Welfare Advisory Committee on Urea Formaldehde Foam Insulation, page 3, April 1981. 2. G.S. Wiberg, Ph.D., toxicologist, Personal Communication. 3. Bo~rdon Chemical, Data submitted to the Canadian General Standards Board Committee, 1979. 4. J. Rybicky and S. Kambanis, Determination of Rate of Formaldehyde Release from UF and PF Foams, Submitted to CGSB Standards Committee 51-GP-24. 5. B. Meyer, "Urea-Formaldehyde Resins," Addison-Wesley Publishing Company Inc., Reading, Mass., Pg. 251, 1979 6. G.S. Wiberg, Ph.D. toxicologist, Personal Communication. PAGENO="0207" 203 APPENDIX A SELECTION OF REMEDIAL MEASURES Each home insulated with UFFI has unique characteristics and is operated in different ways. A number of measurements will be needed in each house to assist in the selection of remedial or preventive measures. These measurements include the formaldehyde gas concentration in. at least 10 wall cavities and moisture content of the wood stud or bQttom plate in the same wall cavities. In some cases measurement of the formaldehyde gas concentration in the air of the living space will also be required. Minimum Action Steps and Remedial Measures are presented in Tables Al to A4 based on measurements from the stud spaces of conventional platform or balloon frame construction. The general concept and strategies can be considered for other situations but may require the a~id of a consulting engineer or architect. The intent of the recommended remedial measures is to reduce the amount of formaldehyde gas, from UFFI, entering the living space. Since health experts have so far been unable to establish the safe concentration for residential environments, the only practical concentration to attempt to achieve is the ambient concentration which would exist if the UFFI was not emitting formaldehyde gas. The Action Steps including remedial measures outlined in the tables, therefore, should be considered as minimum measures. Homeowners are encouraged to go beyond the minimum measures when it is feasible to do so. Use of Tables Al to A4 The formaldehyde gas emission rate from UFFI is affected by both temperature and relative humidity. As the temperature and humidity rise, so will the rate of formaldehyde gas emission. The concentration in the cavity will be directly related to the emission rate. This causes some difficulty when trying to interpret the measurements of formaldehyde gas in the wall cavity. The measurements might be made anytime throughout the year and cannot be made under a standard set of conditions. Measurements made under various temperature and relative humidity conditions must be correlated to the basic relationships between formaldehyde generation rate, relative humidity and temperature in the air of the wall cavities. The moisture content of the air in the cavity should be very nearly equal to the. moisture. content in the outdoor air and so will vary with weather conditions. The outdoor temperature and relative humidity should be measured for each set of measurements. They can also be obtained from the Atmospheric Environment Service of Environment Canada. Table Al outlines the Action Steps and Remedial Measures that should be taken if the moisture content of the wood in the wall cavity is over 20%. In Tables A2 to A4, the required Action Steps and Remedial Measures are based on the "Class" of the UFFI. Five classes, A to E, have been identified. To determine the UFFI class, and thus what action should be taken, Figure Al should be used. This Figure relates the formaldehyde gas concentration to temperature and relative humidity; it PAGENO="0208" 204 - A2 - is based on few data and will be refined as additional information becomes available. The following outline of the procedure uses the data cited in Example 1, details of which are presented later. These data are: temperature - 15°C; relative humidity -- 70%; formaldehyde gas concentration (ppm) -- 0.5. To determine the UFFI class using Fig. Al, proceed as follows: draw a vertical line upwards from the Example temperature (15°C) to where it meets the curved relative humidity line (in this case the RH is 70%). Project a horizontal line from this point to the right to indicate the moisture content on the vertical scale (7.5 kg/kg x 10~). Continue this line to the graph on the right to where it meets the vertical line drawn upwards from the value 0.5 -- the formaldehyde gas concentration in the-wall cavities. The point at which these two lines intersect, designates the class of UFFI -- in this case, Class A. The classes have been defined on the basis of 0°C and 100% relative humidity (moisture content of 4 kg/kg x 1& dry air). At these conditions the regions bracket the following wall cavity concentrations: A - under 0.5 ppm B - 0.5 ppm to 2 ppm C - 2 ppm to 4 ppm D -4 ppm to 6 ppm E- over 6 ppm Once the class has been identified for a particular situation the appropriate series of action steps can be selected from the tables. Table A2 outlines the minimum remedial measures that, barring any complications, should reduce the formaldehyde gas concentration in the living space to near ambient concentrations. Recognizing the uncertainties involved every effort has been made to err on the safe side. Where odours exist it is reasonable to take more caution than if no odour existed. Table A3 gives measures that have a greater safety margin than those in Table A2. Table A4 has even a greater safety margin than the first two because persons suffering medical problems suspected of being related to the UFFI can be more sensitive and can be exposed to a greater risk. The differences between the tables are readily identified by comparing the actions for a corresponding class in each of them. It is emphasized that the people, homes, and material are unique and the ultimate decision on the remedial measures lies with the occupants. If after taking a series of remedial measures there is insufficient improvement in an occupant's health, additional measures are recommended. In some cases interim measures should be undertaken pending the completion of measurements or selection and completion of remedial measures. Interim measures that can be made include pressurizing the house in the summer with a fan blowing through a window, the taping of PAGENO="0209" 205 - A3 - baseboards, the sealing of electrical outlets to reduce infiltration, or the temporary relocation of the affected occupants. Relocation for a week or more, is useful in showing if an improvement in health can be detected when the person is moved to a more formaldehyde-free environment. Adequacy or effectiveness of remedial measures can be confirmed by repeating measurements of formaldehyde gas concentrations in the wall cavity and the living space. The ratio of the concentration in the living space to that of the wall cavity after remedial measures should be much lower than that determined before the remedial measures were taken. In cases where the UFFI is removed, the concentration of formaldehyde gas in the living space after remedial measures should be comparable to the concentrations in the outside air at the same time. If improvements are not sufficient, additional measures will be required. The following are key points regarding the suggested action steps: - where medfcal symptoms are suspected of being related to UFFI, the concentration of formaldehyde gas in the living space and wall cavity should be determined before and after remedial measures. - when fungal growth is identified, a consultant must determine whether and how to treat the wood, and whether the steps outlined in the tables are adequate. - if the measurements of the concentration of formaldehyde gas in the cavities differ, a combination of remedial measures may be required. The measures chosen may differ from one area to another area in the house or be determined by the average formaldehyde gas concentration measured. Example 2 highlights this point. The following examples are based on a number of actual cases but have been simplified to illustrate the use of the remedial measures outlined in the tables. Since actual cases may involve other factors not mentioned, further measures may be required in actual cases. Example 1 Mr. Smith did not have any problems which could be identified with exposure to formaldehyde gas but wanted to take some precautionary measures. * (i) Mr. Smith borrowed a moisture meter and measured the.moisture content of the wood in 10 stud spaces insulated with UFFI. 97-153 O-82---14 PAGENO="0210" 206 - A4 - The readings all indicated a moisture content of below 10%. (ii) He purchased an air sampling pump and tubes for just over $100 and measured the formaldehyde concentration in the same cavities. The readings were all below 0.5 ppm (parts per million) indicating that the foam in the cavities tested was of fairly uniform quality. The temperature and relative humidity on the day of measurements was 15°C and 70% respectively. Using Figure Al the intersection point fell in class A. This indicates the concentration in the cavities was low. Since there were no health problems or odours Table A2 was used to identify the minimum remedial measures for Class A. (iii) He sealed all cracks and openings between the cavities and living spaces. The infiltration of air through the wall cavities was reduced and thus reduced the potential entry of formaldehyde-laden air. Since the original measurements were made on a day with moderate temperature and relative humidity, additional measurements of formaldehyde gas in the stud space were taken in the summer on a hot day. The results were such that the house remained in Class A; no additional remedial measures were necessary at that time. If the concentration were higher, additional measures would be warranted. The sampling pump was used for periodic checks of the cavity concentration and a careful record kept of the measurements and the class from Figure Al. Example 2 Mrs. Jones' child was experiencing medical problems which were believed to be related to the UFFI. (i) the child was taken to a physician The doctor was unable to say whether exposure to formaldehyde gas was the cause of the medical problems but did not discount the possibility. (ii) the general ventilation in the home was increased immediately by installing a fan in a window to blow air into the house. The exposure to formaldehyde was reduced by temporary means to prevent over-exposure while it was determined whether formaldehyde gas was the cause of the child's problems. (iii) the child was sent to spend a week with relatives who did not have UFFI in their homes. An improvement in the child's symptoms was noticed indicating that the symptoms were likely related to the environment in his own `home. PAGENO="0211" 207 -A5- (iv) A consultant was hired to measure the formaldehyde gas concentration in the air of the living space. The operation of the house for the period leading up to the test was specified by the consultant. The formaldehyde concentration in the air of the living space was 0.2 ppm. This measurement was made to check that the formaldehyde was present at a concentration significantly higher than the ambient concentration outside of 0.01 ppm. It was also made to compare with later readings to determine the effectiveness of remedial measures. (v) the consultant also measured the formaldehyde gas concentrations in at least 10 stud spaces The readings for 3 out of 4 walls were below I ppm but in the fourth wall they averaged 10 ppm. For the temperature and humidity conditions present, the fourth wall was in class E of Fig. Al. This indicated that the problem was localized to the one wall and that removal would be necessary as per class E, Table A4. The conditions in the other walls were in class B. (vi) The moisture content of the wood in all four walls was also measured. The wood was dry indicating the high formaldehyde gas concentration was not caused by the presence of moisture. (vii) the consultant cut a test opening to remove a sample of the gypsum board for laboratory analysis of formaldehyde emission. There was very little formaldehyde gas emitted by the gypsum board so the removal of the UFFI from the 4th wall could be done from either the inside or outside. (viii) Mrs. Jones hired a contractor to remove the IJFFI from the exterior under the supervision of the consultant. A copy of NRC Building Practice Notes 19 and 23 on IJFFI were provided to the contractor to outline the procedure to be followed and to emphasise the importance of each step. The rooms of the house along the wall where the UFFI was being removed were pressurized during removal to reduce the amount of UFFI dust entering the living space. Notes and photographs were taken to retain a record of the remedial work. (ix) the contractor was also hired to seal all the cracks and areas of air infiltration on all four walls. Since it was difficult to seal the fourth wall from the outside even with the wall open, it was sealed from the inside in the same way as the three still containing the UFFI. PAGENO="0212" 208 - A6 - (x) a small squirrel cage fan was permanently installed in the basement. By blowing outside air into the basement the negative pressure difference was reduced. A.. small electric heater was installed near the discharge of the fan to heat the incoming air in the winter. A separate fan was necessary for this measure because the house was heated by a hot water system and the furnace had no air circulating fan. (xi) Mrs. Jones washed the ceilings, walls, fl~ors, laundered or dry-cleaned the linens and curtains, vacuumed the rugs and shampooed the upholstery. Most of the formaldehyde clinging to the room surfaces and adsorbed on the fabrics in the living space was removed by this measure. (xii) a second measurement of formaldehyde gas concentration in the living spaces and wall cavities in the three walls with IJFFI was made by the consultant. After these measures, the concentration in the living space was near ambient and the ratio of concentrations between the living space and the wall cavities much smaller. The child's health also showed signs of improvement. Had the child continued to suffer, a doctor should again be consulted and consideration given to implementing other measures such as installation of a heat exchanger coupled with the fan to bring the concentration in the living space closer to ambient. A special air filter system might be required to lower the concentration below ambient concentrations. PAGENO="0213" 209 TABLE Al. ACTION STEPS AND REMEDIAL MEASURES -- Moisture Content of Wood Over 20% Reference(s) Action Steps I Remedial Measures to text 1. Cut test opening in stud space where moisture content is highest or where there is visible evidence of fungus growth 6, 7, B4 - Submit samples of wood, UFFI and other infected material for fungus identification .... B4 2. If fungus growth is found, hire a consultant to deal with problems 6 3. If no serious fungus growth is found, proceed with drying cavity as follows: (a) Check (or have consultant check) for sources of moisture and correct as appropriate B6 (b) Dry section of wall until wood moisture content is between 10 and 15% B6 (c) Close cavity (d) At least one day after step (c), recheck formaldehyde gas concentration in the wall cavity to determine effect of drying on g~s concentration 8, 10 Consult Tables A2 to A4 to identify the remedial measures required Al - A6 If removal of the UFFI is warranted, there is no benefit from drying all cavities. (e) If removal is not warranted, dry all cavities with moisture content above 20% B6 (f) Close cavities - Recheck formaldehyde gas concentration in cavities 8, 10 (g) Proceed with remedial measures to control formaldehyde gas based on new measurements .. Tables !~2-A4 PAGENO="0214" 210 TABLE A2. ACTION STEPS AND REMEDIAL MEASURES -- No Medical Problems, No Odour from UFFI seal exterior wall seal interior partitions increase ventilation by use of forced air furnace measure formaldehyde gas concentration in living space if not near ambient: install forced ventilation with or without heat exchanger - measure formaldehyde gas concentration in living space - seal e~terior wall - seal interior partitions - increase ventilation by: forced air furnace OR forced ventilation with or without heat exchanger - remeasure formaldehyde gas concentration in living space if not near ambient: install chemisorbent filter OR remove UFFI Class, from Fig.Al Reference(s) to text D Action Steps F, Remedial Measures A - seal exterior wall 18-20 B - - seal exterior wall increase ventilation by use of forced air furnace 18-20 2O22 C - seal exterior wall 18-20 - - seal interior partitions increase ventilation by use of forced air furnace 20 20-22 18-20 20 20-22 8, 10, Bl, B2 31, Al, A3 22~23 E 8, 10, Bl, B2 18-20 20 20-22 22-23 8, 10, BI, 82 31, Al, A3 23-24 25-31 PAGENO="0215" Reference(s) Action Steps S Remedial Measures to text - seal exterior wall - increase ventilation by use of forced air furnace - seal exterior wall - seal interior partitions - increase ventilation by use of forced air furnace - seal exterior wall - seal interior partitions - increase ventilation by: forced air furnace OR forced ventilation - measure formaldehyde gas concentration in living space - seal exterior wall - seal interior partitions - increase ventilation by: forced air furnace OR forced ventilation remeasure formaldehyde gas concentration in living space if not near ambient: increase forced ventilation with heat exchanger OR install chemisorbent air filter - measure formaldehyde gas concentration in living space - seal exterior wall - increase ventilation by: forced ventilation OR forced ventilation with heat exchanger - remeasure formaldehyde gas concentration in living space if near ambient, proceed with sealing interior partitions if not near ambient: install chemisorbent filter OR 211 TABLE A3. ACTION STEPS AND REMEDIAL MEASURES -- Odour from UFFI Present Class, from Fig.Al C 18-20 20-22 18-20 20 20-22 18-20 20 D 20-22, 22-23 8, 10, B1, 82 18-20 20 8, 10, 81, 82 31, Al, A3 22-23 * 8, 10, B1, B2 18-20 22 22-23 8, 10, Bi, 82 20 31, Al, A3 23-24 PAGENO="0216" 212 TABLE A4. ACTION STEPS AND REMEDIAL MEASURES -- Medical Symptons Apparently Related to UFFI NOTE: In cases involving medical problems the formaldehyde gas concentration in the air of the living space should be checked before proceeding with remedial measures. Class, from Reference(s) Fig.Al Action Steps S Remedial Measures to text A - seal exterior wall 18-20 - increase ventilation by use of forced air furnace 20-22 - clean interior surfaces 30-31 - remeasure formaldehyde gas concentration in air of living space 8, 10, Bl, B2 if not near ambient or persons still reacting: 31, Al, A3 seal interior partitions 20 remeasure formaldehyde gas concentration in air of living space 8, 10, 81, B2 B - seal exterior wall 18-20 - seal interior partitions 20 - increase ventilation by use of forced air furnace 20-22 - clean interior surfaces 30-31 - remeasure formaldehyde gas concentration in air of living space 8, 10, 81, B2 if not near ambient or persons still reacting: 31, Al, A3 provide forced ventilation with or without heat exchanger 22-23 OR install chemisorbent filter 23-24 C - seal exterior wall 18-20 - seal interior partitions 20 - provide forced ventilation 22-23 - clean interior surfaces 30-31 - remeasure formaldehyde gas concentration in air of living space 8, 10, Bi, B2 if not near ambient or persons still reacting 31, Al, A3 increase forced ventilation with heat exchanger 22-23 OR install chemisorbent filter 23-24 D - seal exterior wall 18-20 - seal interior partitions 20 - provide forced ventilation with heat exchanger 22-23 - clean interior surfaces 30-31 - remeasure formaldehyde gas concentration in air of living space 8, 10, 81, B2 if not near ambient or persons still reacting 31, Al, A3 install chemisorbent filter 23-24 OR remove UFFI 25-31 E - sample material from wall for formaldehyde emission test .... 11, 84 - remove UFFI 25-31 - clean interior surfaces 30-31 - remeasure formaldehyde gas-concentration in air of living space 8, 10, Bl, 82 if not near ambient or persons still reacting: 31, Al, A3 check for UFFI missed in other locations 26, 02 check for internal sources of formaldehyde gas, e.g. furniture 26 PAGENO="0217" c_)~-4 >< r ~ > >`J,~ ~ >2= : - <-4 m ~0 = C -4 = > -4 ~- C, >~ -4 1.,, -v > -4 = 0 > -,- m >-< - 0 rn C) >> ~ 0 L1~ ~ - C) -~ -4 > -4 0 - r~ r%~ r,) NJ C' 0 ~ 00 Ni A R MO I STURE CONTENT, kg/kg x 1O3 ~J1! C-, > ~i1 0 ~?1 = -n C' 00 0 ~Tg PAGENO="0218" 214 APPENDIX B SUMMARIES OF SUBJECTS TO BE COVERED BY FUTURE PUBLICATIONS ON UFFI 1. Measurement of Moisture. Content in Wood Moisture meters are simple electrical ohmmeters which measure the electrical resistance between two needle-like probes. Probes are available with needles of various lengths. Probes having insulated needles except for the tips can be driven through the gypsum board or lath and plaster into the wood stud or plate at the bottom of the cavity and a reading of the moisture content taken. If the probes are too short to penetrate through the interior finish, the baseboard should bç removed and a section of interior finish cut away to allow the probe to enter the wood. This should be done so that the cut-away and any sealing is covered when the baseboard is reapplied. 2. Measurement of Formaldehyde in the Living Space NIOSH* Chromotropic Acid Method The most common method of measuring formaldehyde gas in the living space is the NIOSH chromotropic acid method. The method, simply stated, involves: i) passing a known volume of air through a solution that collects the formaldehyde gas from the air and ii) developing the solution using a laboratory procedure to yield a coloured solution, then reading the intensity of the colour using photometric methods and based on the intensity, determining the formaldehyde concentration. The sampling time is normally a number of hours to allow sufficient volume of air to pass through the solution. New Methods Instrument companies are in the. process of developing detectors with improved accuracy, sensitivity, portability and more convenient sampling procedures. Detectors operating on the principle of gas diffusion through a membrane or tubes into a solution are receiving greater recognition. House Preparation When measuring the concentration of formaldehyde gas in the living space, it is preferable that it be don~ under worst-case conditions. Unfortunately, the interrelation:ship of the mechanisms causing high formaldehyde gas concentrations in the living space are not completely understood so are difficult to predict. Worst-case weather conditions seldom occur when measurements are required. Worst-case conditions "under prevailing foam and weather conditions" are therefore *National Institute of Occupational Safety and Health PAGENO="0219" 215 - B2 - the best that can be readily measured. Guidelines to encourage the worst-case conditions are offered. In each case the testing agency must carefully consider unique features of the building whichmay affect the results. The preparation of the house should be adjusted as appropriate. The following is offered as a general guide: a) For 18 hours before and during the test: - maintain the house temperature at a steady temperature of at least 20°C (no night set-back of thermostat) - keep all windows, fireplaces and vents closed - turn circulating fan on forced air furnaces to normal rather than summer circulation - do not operate ventilation fans, generate any smoke by frying or broiling, or operate automobiles in attached garages - do not use gas stoves, fireplaces or other combustion equipment with the exception of the furnace. - do not paint - do not smoke in the house b) During the Test: - take measurements only if windspeeds are less than 25 km/h - take air sample in mid-afternoon if in winter; morning or mid- afternoon if in summer. - set thermostat back to 14°C to ensure furnace does not operate during sampling; operate air conditioners with 100% recirculat ion. c) Number of Samples: - a minimum of one air sample per floor should be taken close to the centre of the floor. A measurement of the outside ambient concentration is not essential unless no information is available for that region or unusual conditions exist. The UFFI may emit gases other than formaldehyde which can cause similar reactions in the occupants and may also interfere with the measurement of formaldehyde. In cases where the medical reactions seem to be related to the environment in the living space, the formaldehyde gas concentration seems too low to have been the cause, and investigations do not identify any fungal growth, measurements should be made for other gases. Other sources of gas such as sewer gas, exhaust from furnaces or vapours from insecticides should be investigated. 3. Measurement of Formaldehyde in the Wall Cavity There are two types of hand-held instruments for measuring formaldehyde which provide results in a short time period. These are simple to operate and the measurements are inp'rn~'~" PAGENO="0220" 216 - B3 - The first type is a hand-operated air-sampling pump using gas detection tubes. A specific volume of air is pumped through a detection tube containing chemicals which react with one gas or a family of gases and produce a known colour change. The gas concentration is determined by either of two methods and depends on the make of equipment. Either the volume of air required to produce a specific colour change in the tube is measured or the length of the column of chemical that changes colour is measured. The sensitivity of the gas detection tube and the range varies from one manufacturer to another. The following gas detection tubes are currently available: Company Rangy Drager: high range 2 - 50 ppm low range 0.5 - 10 ppm Gastec 2 - 20 ppm Kitagawa 1 - 35 ppm Mine Safety Appliances 1 - 100 ppm The accuracy of these detectors is poorer than N~t0S}I but they do provide a reasonable indication of the concentrations. The tubes are sensitive to temperature and humidity, so the manufacturer's instructions should be.closely followed. In some cases, the colour change in the tube will be different than that specified for formaldehyde gas. For example in the Drager system the proper colour change is from white to pink whereas the presence of other specific gases can cause a colour change from white to orange, yellow or brown. Whenever this occurs, other types of tubes or specialized sampling equipment will be required to identify the gases present. Heavy gases may collect at.the bottom of the cavity so a second sample at least 1.5 m higher in the same cavity may be required to determine formaldehyde gas concentration. To make a mesurement using a gas detection tube instrument, a hole the size of the detection tube is drilled into the stud space and well into the foam. The detection tube is inserted immediately into the wall cavity and an air sample taken. Upon removal of the tube the hole should be immediately covered with tape. Care should be taken to prevent short-circuiting of air from the room into the hole in which the detection tube is inserted. If the hole drilled is too large, it should be covered with a piece of tape and the detection tube inserted through a smaller hole punctured in the tape. Daylight from a window or a standard light source should be used to observe the colour change in the tube. While the tube is removed to observe the colour the hole should be temporarily covered with tape. A newer instrument, developed by Lion Laboratories in collaboration with Ciba-Geigy Plastics and Additives Company, is the Formaldemeter. This instrument uses a fuel cell detector and jrovides the reading in a digital display. The accuracy is similar to that of the detection tubes. The concentration is equal to the peak value displayed after.approximately 20 seconds. Like the detection tubes, this device is also subject to interferences from other gases. This may be indicated by a peak reading being displayed at considerably shorter or longer, than 20 seconds. A number of minut~ m,ic- "-P' ~ PAGENO="0221" 217 -B4- readings to allow the fuel cell to discharge. The time required depends on the concentration measured. With the Formaldemeter, only a small air sample is required. A needle similar to the type used to fill footballs and basketballs can be used for walls which do not have multilayer sheathing. The needle is inserted into the wall cavity through a small pilot hole the same size as the needle and then connected to a pump by a short length of tubing. The Forinaldemeter air sample is taken from a sampling port in the tubing after the flow has come to equilibrium and the pump shut off. A hand pump can also be used. Cavities, including ceiling spaces, can be checked with either method to determine if a problem is general throughout the house or localized in a few cavities. Measuring concentrations in the ceiling cavity near the wall may indicate the presence of UFFI in the ceiling or floor space if the concentrations are comparable to the wall cavity measurements. 4. Test Opening and Material Sampling Test openings will generally be used for the following: - obtaining samples for fungal identification - checking for visible problems - sampling interior sheathing for determination of formaldehyde gas emission in a laboratory Where possible, a location should be selected that is easily repaired and the finish not critical to a room's appearance. This might be in a closet or behind a piece of furniture. The location of electrical outlets and wires in the basement should be used to determine if there are electrical wires in the cavity before cutting. The opening should span a stud space, be at least 300 mm high, and should be located at the bottom of the wall just above the baseboard so that the bottom wall plate can be observed (Figure B-l). Each of the materials removed in making the opening, such as gypsum board (or lath and plaster), UFFI and sheathing should be placed in separate sealed plastic bags. The bags should be labeled and kept in case they are required for the formaldehyde emission measurements. The surfaces of the bottom plate and studs should be brushed clean and checked for rot, fungal growth or unusual discoloration. In the following situations samples of material from the test opening (UFFI, wood, paper) should be submitted to a fungal identification specialist: - where the wood is discolored and/or feels damp several large slivers should be obtained - where the UFFI, which is normally white, off-white, or blue, has turned grey, black or green, a small piece (less than 100 mm square and the thickness of the cavity) of the discolored foam should be obtained PAGENO="0222" 218 - B5 - - where fungal growth or insect infestation is evident, small samples (less than 100 mm square) of each kind of organic material in the test opening should be obtained. These would include slivers of wood from studs, paper from any existing insulation, UFFI, and a 25 mm square of exterior sheathing material. Agriculture Canada provides a fungal identification service for the Canadian public. The specialist will determine the species of fungus, food source and whether the fungus has been active or dormant. At the time of writing this publication there was no charge for the service. The samples to be submitted for fungal identification should be placed in separate clean unused plastic bags punctured to supply air to the fungus and to prevent the humidity in the bag from rising too high. They should be shipped to the following address with complete information on when the UFFI was installed, pictures if available, date samples were removed, location in structure and a description of the building construction: - Director, Biosystematic Research Institute, National Identification Service, Agriculture Canada Wm Saunders Building, Central Experimental Farm, Ottawa, Ontario. K1A OC6 After all observations have been made and samples removed, the opening should be filled with a batt-type insulation and temporarily sealed by taping polyethylene over the opening. Once the investigation of the problem is complete and the remedial measures identified, the test opening can be permanently repaired as appropriate. 5. Optical Probes Optical probes for use in inspecting wall or other cavities in the building envelope are similar to the types used by the medical profession. They allow visual or photographic observations of the cavity without causing serious damage to the sheathing. The probe is inserted through a hole approximately 15 mm in diameter. The hole is easily repaired and the surface refinished so that little evidence of entry is apparent. When the presence of moisture is suspected, a series of cavities can be checked by drilling a hole just above the wall's bottom plate, moving the insulation away from the bottom plate with a screwdriver or wire probe, inserting the optical probe and inspecting the plate. Where moisture or fungal growth is apparent, the cavities should be opened for further investigation. Optical probes are expensive and so are probably only practical for use by consultants and contractors. PAGENO="0223" 219 - B6 - 6. Drying Wet Cavities Before a cavity is dried the source of moisture should be identified and, if it is rain or air leakage, corrected. The quickest way to dry the wet cavity is to force warm dry air to flow through the cavity to the outside. It is not always possible to preheat the air used for drying. It would be advisable to experiment with a section of the wall to determine if drying is effective and then to remeasure the concentration of formaldehyde gas in the cavity. This will indicate whether moisture was the cause of high concentrations. If, after drying, the formaldehyde gas concentrations are still high enough to warrant removal of the UFFI, there is no benefit in trying to dry all the cavities unless the high concentrations are localized to one part of the house. The following techniques, although not fully evaluated at time of publication, will provide an indication of various methods which could be considered. Method 1 - forced ventilation by connecting stud spaces to a manifold and drawing air through the cavity and discharging to the atmosphere Method 2 - drill a hole into each stud space through the inside surface about 50 mm above the floor level. Using a fan, in the summer pressurize the living space or in the winter depressurize the living space. Depending on formaldehyde concentrations, the occupants may need to be temporarily relocated if the house is being depressurized. Method 3 - if exterior is siding, open the wall cavity from the exterior at the top and bottom to allow air to circulate freely. The openings must be protected from the weather and the interior surface of the wall sealed to reduce the uncontrolled flow of air into the living space. Once the cavity is dry (10 to 15% moisture content) the holes through the sheathing should be sealed and cladding restored. PAGENO="0224" INTERIOR GYPS BOARD OR LATH AND PLASTER 220 CAVITY CONTAINING UFFI BOTTOM WALL PLATE BASEBOARD FIGURE Bi TEST OPENING PAGENO="0225" 221 APPENDIX C FUNGI ISOLATED FROM UFFI Problems involving fungi associated with UFFI have been rare but some cases have occurred. Homeowners experiencing medical problems should not assume, therefore, that fungi are present but should consult with the appropriate experts as discussed in the text. The following information, prepared by Health and Welfare Canada for NRC, is provided in this document as an assistance to the consultants or experts because of the difficulty in obtaining and scarcity of information on the species identified. Alternaria spp. - agenus of dematiacious Fungie Imperfecti of the order Moniliales. It~ causes several diseases of plants and has been reported in diseases of the lungs and in skin infection in man, and is also a common allergen in human bronchial asthma. Aspergillus spp. - causes a diseased condition marked by inflammatory granulomatous lesions in the skin, ear, orbit, nasal sinuses, lungs, and sometimes in the bones and meninges; called also aspergillomycosis. ~pergillus versicolar - a species of common soil saprophytes often isolated from dried salted beef. Cladosporium resinae - found in kerosene-type fuel from jet aircraft. Paecilomyces varioti - common fungus in the air, soil, compost, wood and food-stuffs. Although generally considered as a saprophyte, it can apparently become pathogenic in man and animals, causing paecilomycosis. Penicillium spp. - may cause a pulmonary infection called penicilliosis. Paecilomyces farinosus - causes a mycotic disease in man and animals called paecilomycosis. Trichoderma spp. - a genus of soil fungi, some species of which cause alimentary toxic aleukia (absence of leukocytes - white cells - from the blood). 97-153 O-82--15 PAGENO="0226" 222 APPENDIX D COMMON TYPES OF HOUSE CONSTRUCTION 1. Platform Frame (Figure Dl) Description: Platform frame construction is the, most common type of wood frame house construction. A house is constructed by erecting the walls for each storey from the platform formed by the flooi~ joists and subflooring. The subfloor is placed on the platform before erecting the walls. The walls consist of studs, usually at 400 mm on centre, with top and bottom plates, the cavity is jnclosed by lath and plaster or gypsum board on the interior, and sheathing on the exterior. The UFFI was usually installed in the cavity between the studs although there have been cases of UFFI installed between brick veneer and the exterior sheathing. Comments: - where board subflooring is present, it will be necessary in some cases to seal between the boards on both sides of the wall plate. This will require special techniques and equipment, now being studied. The effectiveness of a continuous gasket or bead of sealant applied along the base of the wall behind the baseboard, will be reduced by air infiltration between the boards. - where it is necessary to remove UFFI placed between brick veneer and the sheathing, it will have to be done from the exterior. 2. Balloon Frame (Figure D2) Description: - Mány.older houses were constructed using this approach. On the first floor, the joists sit on the bottom plate of the wall and are nailed to the studs. The joists extend to the outside of the wall. The stud spaces were sometimes fire stopped at the floor levels. Although required by building codes this was often omitted. In some cases nailer strips were installed to carry the subflooring between joists. The joist space is not closed at the wall line and is open to the wall cavity. The wall studs are continuous through the second floor line and the second floor joists are set on a ledger let into the studs. Comments: - this type of construction is very difficult to seal adequately due to the connections between wall cavity and joist spaces. More emphasis on pressurization is necessary. PAGENO="0227" 223 - 02 - - floor spaces may have been insulated due to the connection between the gall cavity and joist spaces. These should be checked. 3. Plank Frame (Figure D3) Description: Plank frame construction consists of vertical posts approximately 250-350 mm in width, spaced at 2.5 to 3 m intervals supporting lintels approximately 250 mm in depth. The space between the floors was then filled in with planks from post to post. The space between the joists at the exterior wall was commonly filled with solid blocking. Furring strips were placed on the interior surface before applying lath and plaster or gypsum board. When the exterior cladding was brick veneer, UFFI was installed between it and the plank wall. In other cases it was installed between the inside surface and the plank wall in the cavity created by the furring. Comments: - where UFFI is located between the brick veneer and the plank wall and removal is necessary, it will have to be done from the exterior. - the location of the UFFI will affect the success of sealing the exterior wall as a remedial measure. - if the solid blocking between the joists was omitted, or knocked down during UFFI application, UFFI may have entered the floor space. 4. Masonry Description: Masonry construction is characterized by exterior walls of multiple wythes of brick or concrete block or a combination of both. The wall may or may not contain an airspace. Furring strips of about 20 mm are fastened to the masonry and the interior lath and plaster applied to them. The cavities that were insulated with UFFI included the 20 mm space between the interior finish and masonry and the cavities within the masonry wall. Comments: - UFFI installed in cavities enclosed by masonry such as the cores of concrete block walls or between wythes of masonry is, in most cases, very difficult if not impractical to remove. - the joist space may be connected to the wall cavity cr~eated by the furring strips and may require additional effort to seal. - pressurization of the living space will minimize infiltration in most of the areas which cannot be sealed effectively. PAGENO="0228" 224 BOTTOM WALL PLA~ FIGURE Dl PLATFORM FRAME CONSTRUCTION BOTTOM WALL PLATE, BLE PLATE IBLE PLATE FROM FoUNDAT:N~~JOISTB~R~ON BOTTOM WALL PLATE FIGURE D2 BALLOON-FRAME CONSTRUCTION PAGENO="0229" 225 FIGURE D3 PLANK FRAME CONSTRUCTION FIGURE D4 SOLID MASONRY CONSTRUCTION PAGENO="0230" 226 INDEX Absorption 5, 11 Adsorption 5, 30 Air change 16, 18, 22 flow 4, 5, 7,8, 14-16, 21, 22 infiltration 4, 5, 8, 12, 16, 18, 20-22, 24, 28 leakage 4, 5, 7, 10, 12, 14, 18, 20, 23, 28, 32 movement 4, 5, 8, 20 Ambient 10, 17, 26, 31, 33 Ammonia 26 Attics 7, 8, 25, 32 Balloon frame 8, 18, Appendix D Below grade 7, 8 Canadian General Standards Board 7, 10 Canada Mortgage and Housing Corporation 7 Canopies B Cathedral ceilings 7, 16, 32 Ceilings 7, 16, 20, 27, 29, 32 Class 11, Appendix A Cleaning 25, 30, 31 Concentration 3, 24 formaldehyde in cavities 7, 8, 10, 11, 14-16, 20, 25, 26, 31-33, 83 formaldehyde in living space 8, 10-12, 14-18, 24-26, 31-33, 82 Condensation 5, 7, 12, 21 Construction 4, 8, 18, 20, 25, 30, 31, Appendix D Corrosion 6, 27, 29 Degradation 4, 8, 27, 29 Diffusion 3, 4, 7, 12, 20 Drying 5-8, 16, 26-28, 30, B6 Electrical 5, 6, 18, 27-30 Emission 3-5, 8, 11, 14, 20, 24, 26, 28 Endoscope 6 Exposure 3, 8, 24, 26, 32 Fans 8, 16, 18, 21-23, 29, 32 Filters 16, 23, 24, 31, 32 Fireplaces 8, 22 Floors 8, 18, 20, 27-29 Formaldehyde in cavities 7, 8, 10, 11, 14-16, 20, 25, 26, 31-33, B3 in living space 8, 10-12, 14-18, 22-26, 30-33, 82 diffusion 4, 12, 20 emission 4, 5, 8, 10, 11, 14, 20, 28 exposure 3, 24, 32 infiltration 4, 8, 12-18, 24, 32 odour 3, 5, 30 sensitivity 3, 12, 20, 23, 26-29, 32 Fungus 3, 5-7, 12, 27, 29, Appendix C Furnace 4, 8, 21, 22, 31 PAGENO="0231" 227 INDEX --page2 Health 3, 5, 10, 11, 26 Heat exchanger 22, 23 Humidity 4, 7, 8, 10-12 Infiltration 4, 5, 8, 12, 16, 18, 20-22, 24, 28, 29 Interim measures 18, 31 Measurement 6, 8, 10, 16, 26, 31-33; Appendix B Medical 3, 24, 30, 33 Moisture 3, 5-7, 11, 12, 32, 33, Appendices A F, B Moisture meter 6, B1 Odour 3, 5, 11, 20, 26, 30 Opening 6, B4 Operation 4, 5, 10 Optical probe 6, B5 Overhangs 8 Partitions 8, 20, 21, 25, 27-30 Precautions 3, 26, 32, 33 Pressure 4, 12, 16, 20-23 Pressurization 12, 17, 22, 28, 29 Preventive 32 Protective 25, 26, 28, 32 Remedial measures 6, 10-12, 16-18, 25, 30, 31, 33, 34, Appendix A Removal 8, 10, 11, 18, 20, 24-33 Resin 3, 4, 6, 11, 29 Roofs 7, 16, 32 Samples 6, B4 Sealing 8, 12, 16-20, 22-25, 27-30, 32 Sensitivity 3, 12, 20, 23, 24, 26-29, 32 Sodium bisulfite 25-28, 30, 32, 33 Sodium sulfite 26 Structure 5, 27-29 Temperature 4, 7, 10-12, 21, 27, 30 Test 6, 10, 11, 24, 26, 31, 33 Thermal resistance 4 Treating 25-28, 30 Ventilation 5, 16-18, 21, 22, 26, 27, 29, 32 Walls 8, 18-20 Water 5, 7, 8, 11 Windows 16, 20-23 Wood 5, 6, 11, 25-30, 32, 33, Bl PAGENO="0232" 228 Mr. ROSENTHAL. Thank YOU all very, very much. We are very grateful for your coming here. Our next panel of witnesses consist of Dr. Hugh Westgate, Dr. Richard Griesemer, and Dr. Peter Breysse. Will we meet you outside at your home? I have not made up my mind how I am going to handle this thing. Mrs. LoVEJOY. We will open the doors for you. We will be waiting outside for you. Mr. ROSENTHAL. Dr. Westgate, it says here that you are first. We are delighted you are all here. We are very grateful for your par- ticipation here. Dr. Westgate. You may proceed. STATEMENT OF HUGH D. WESTGATE, M.D., ANESTHESIOLOGIST, CHILDREN'S HEALTH CENTER, MINNEAPOLIS, MINN. Dr. WESTGATE. Thank you, Mr. Chairman. I am a physician in the private practice of anesthesiology, pri- marily at the Children's Health Center in Minneapolis, Minn. I am the director of sudden-infant-death research for the upper Midwest area, the Minnesota area and west. It was through this re- search that my interest in the formaldehyde problem came into effect. My only interest is as a clinician and from a background of treat- ing parents and patients. My background has been as a consultant to the U.S. Consumer Product Safety Commission and I was partly responsible for the pe- diatric portion of the JRB Associates consultation to the national group, U.S.C.P.S.C. I have also been a part of the standards setting mechanism within Minnesota. After the earlier comments, I believe I am one of those physi- cians that does know a small amount about urea formaldehyde. I have been asked to comment on specific questions for the com- mittee. Rather than reading anything specifically, I wanted to answer those questions. Since January 1979 I have seen directly, to some extent, about 145 families in Minnesota. I have had less experience with, but I probably have had another 75 to 80 families around the United States with children involved in what has felt to be, to some degree, symptoms of formaldehyde poisoning. Mr. Barnard, you asked about how people are affected-I think it is more reasonable to indicate as a clinician what my response is to disease. Basically we believe in a holistic concept of medicine. There are probably three actions or three things that cause a disease. One is the host, or ourselves; one is an agent, which could either be a bacteria or a virus or a contaminant, such as formaldehyde; and thirdly, there is the interaction with the environment. We take into account the host response, what the psychological part of that individual is, plus the physical response of the individ- ual. These will vary the response. PAGENO="0233" 229 Basically there probably are three responses in the disease proc- ess. One is the cause and effect relationship, a dose-time type of re- sponse. We see this, to some extent, with formaldehyde. If you leave a human being in formaldehyde with a level of about 0.05 parts per million, about 65 percent to 75 percent of those individuals will have watery eyes. If you place the individuals in a level of about 0.3 parts per mil- lion to about 0.5 parts per million, those individuals will, in a high percentage of cases, have a burning within their chest. This is the mechanism that the OSHA and NIOSH standards are based on. Mice are left within an environment of formaldehyde and the point where they have a 50-percent reduction in their breath- ing is the level that industrial standards will set as the so-called maximum concentration. This is the level on which the threshold limit value has been set by all industrial standards and which presently is the method by which the industrial standards for formaldehyde have been set. We see that type of response in anaesthesia. When we put a pa- tient to sleep we know that if we give a certain percentage of the gas to the individual they will go to sleep. We know that if we give them a higher percentage their heart will stop. That is a dose response type of curve. There is a second type of response which is one in which individ- uals, if they are left in an atmosphere, will adapt and accommo- date to a level. This is seen both in formaldehyde and in disease processes. We have it with children with epilepsy where you give phenobar- bital and they can take a higher and higher dose of this. You see it in chemical dependency where people would also have the same effect. They require large doses that would knock out any other in- dividual. We see this in individuals with formaldehyde. Perhaps some of it is their psychological response, in that there is a desire to tolerate an atmosphere that is greater than normal. And over a period of time they will tolerate that. This is both good and bad. There are some types of contaminants and drugs that will induce the enzymes in our body to break down other products and other drugs. Those breakdown products will often cause toxic effects and will cause side effects on their own. They will sensitize cells to perhaps other things, such as cancer as well. Then lastly there is a group-and you have heard to some extent those this morning-a group of patients who it does not matter what level of a contaminant or a disease that you put them into, they will respond very abnormally to very small levels. The only way to treat those patients is to remove them. The com- monest one that we all know about is an allergy to penicillin. There are some individuals that will die just from a very small dose of penicillin. That is a hypersensitive type of response. So with this background, we see in children and small infants a very specific group. These infants are very sensitive to the atmosphere probably be- cause they might have developmental defects. Also, for instance, PAGENO="0234" 230 their brain stem, the areas of their brain that control their heart and their breathing are not normally developed. They will respond with a lack of breathing, or so-called apnea, to very low concentrations of environmental contaminates; to high humidity, to high temperatures; to things that are burning in a home or to a viral disease. Those individuals, I feel, are a very specific group of people that have to be protected. I believe that any level of formaldehyde above a level of about 0.1 parts per million is grossly abnormal for those patients. Within the State of Minnesota, we have no difficulty in removing children from homes in which the level is that high. We also-or at least myself-feel that if an individual has symp- toms of an environmental contaminant and when we remove that child from the atmosphere, he becomes well, as you have heard this morning, without therapy. We have reasonable cause and effect. If you reintroduce that individual to the environment and they get the same symptoms again, in my mind that is enough cause and effect to treat that individual as a patient and remove them from that atmosphere permanently. I do this both for medical reasons as well as an indication of medical legal responsibility. We, in January 1979, within our State had a group of twins, one of whom died from sudden infant death and the other who sur- vived. I am attempting to collect enough of these patients to make it a statistically significant group. Within that group I had a patient referred last January whose brother had died in a mobile home in Minnesota. That child had a very different type of history when I took it from the mother. This was completely different and completely unrelated to a sudden infant death or a crib death. The baby was placed in the back room of the mobile home which had never been used. The next morning when he did not awaken, the mother went in and found him quite lethargic. He would not respond. He was ashen gray and pale. She took him out and he recovered and by night he was eating again. So the mother put him back in the room the next night and the following morning he was found dead. This was before there was any testing available. I hired a private firm who tested the levels. I thought it was probably carbon mon- oxide that had done this. The carbon monoxide was zero in the home and the level of for- maldehyde in the baby's bedroom was about 0.23 parts per million. We tested the surviving twin and that twin had an immature type of brain so that if one could postulate-and it is only a postu- lation-the twin that died probably had some defect also. We have seen children who have been put into the homes with very low levels, 0.18 parts per million, that have developed severe asthma and have had to be hospitalized. We have seen other histories of patients-I have perhaps 8 or 10 deaths-none in which there is as a direct cause and effect rela- tionship as in the initial baby. PAGENO="0235" 231 You were asking, Mr. Chairman, about who would buy the homes. The home of that family was taken back by the mobile home manufactuer. It was then sold to another family with small children without disclosure after the initial child had died in the home. The second family has since moved out. We have seen older patients with chronic obstructive lung dis- ease or emphysema, who have used their life savings to buy a mobile home and those individuals are extremely sensitive to the formaldehyde or to any contaminant. We have seen those people lose their life savings by not being able to live in their homes. We have many histories where there has been fetal loss or mis- carriages. Two to three miscarriages in a mobile home, with the parents moving out and then having a perfectly healthy baby. We have a great number of families with children that have had persistent lung problems, chroniô lung diseases, and gastronintes- tinal upset, which is a common symptom in children. When you remove them, they become fine. When you leave them out, or take them out of the atmosphere, they do not have their symptoms. When we reintroduce them, which we have done on a number of occasions with the parents' permission, the symptoms would return and once again removing them, and they are fine. I feel that at the present time we certainly have families who have probably shown some degree of adaptation with convulsions. Over a 6-month period of time in these individuals the convulsions will tend to disappear. They have been thoroughly worked up. In fact, we have one family whose father was a neurologist and the mother a pediatri- cian. They had two youngsters when they moved into a geodetic type home, developed convulsions. Over a 6-month period or an 8-month period, the convulsions disappeared without any treatment. The individuals then become healthy. We have had levels in the mobile homes anywhere from about 0.15 to up to 3.8 parts per million. Mr. Hiler was asking about the use of formaldehyde insulation in urea formaldehyde. We do not know of any mobile homes in Minnesota that had it initially. We. have homes in which it has been placed in afterwards, which is a dastardly thing to do because basically the mobile home has a metal outside hull and all the leaching and all the gases that escape come into the inside of the home. At least with .a conventional home, some of it leaches outside. We have had levels in mobile homes as high as 3.8 parts per mil- lion. We have had indications of homes, I know of one home in Idaho Falls, in which the level was 10 parts per million. It cost that individual $30,000 for complete removal of all that insulation. We have just received a letter from a family in Michigan in which the levels are 1.2 and 1.8. They have a history of two chil- dren who have had abnormalities, both brain and congential abnor- malities. Whether or not this is related, I do not know. PAGENO="0236" 232 We have had a family in Virginia that has two children that have had chronic disease over about 1½ to a 2-year period that we have just suggested to their legal counsel that they be removed from the home hoping that an improvement would take place. One of the difficulties was that when we first heard of these symptoms I went to the literature to find out what the industrial standards were. I could not understand why we in this country would have indus- trial standards that were quite strict and would have nothing for the consumer. The industrial standard of 0.3 parts per million which was then in effect, based on the total amount of air that a worker would breathe, and if we were to take the industrial hygenic literature at that point, then the maximum level that we should have for a con- sumer, an adult consumer, would be between 0.3 and 0.03 parts per million. I think the 0.3 parts per million is the maximum that we should be allowing any consumer to be in simply because that is what we have said that healthy young adults can be in. NASA has an amount of 0.1 parts per million as their maximum allowable concentration. The U.S. Navy has a concentration, I be- lieve, of 0.5 parts per million. These are all healthy young people in an ideal physical state and exposed for shorter periods of time. With the exception of NASA and the Navy, consumers are exposed for longer periods. The industrial standards, I think, have set at least a basic mini- mum. I think that no consumer should be allowed to be in an at- mosphere greater than 0.3 parts per million. NIOSH has suggested that this should be lowered to about 0.1 parts per million. I think that is very reasonable. I do not believe that any child or any individual who has shown any allergic responses or any individual who has an obstructive lung disease, such as our older population or any pregnant woman, particularly during the first trimester of life when the baby is being formed, should be in a level greater than 0.1 parts per mil- lion. I have accepted those levels based on what I think are the amount of air that those individuals would be breathing and are comparable to what we have set for industrial standards, which is all that I have to go on. Parents of two small children recently came to us and asked us what our suggestion was regarding buying a mobile home. We sug- gested that they not take the children into the home. They went ahead and bought the home and the children have been sick enough to have to be removed from the home. I do not believe that these individuals in our society have any recourse at all. I believe they have made a conscientious judgment. They had all the knowledge that was needed. I do not believe they should have special consideration. On the other hand there are many people who have not had that knowledge, particularly in the past, and particularly those individ- uals who are older and who have put their life savings into retire- ment mobile homes and to the younger people who I think particu- larly are at risk. These people should be protected. PAGENO="0237" 233 Those, Mr. Chairman, are my feelings and my statement. I would ask that my prepared testimony be placed in the record in its en- tirety. Mr. ROSENTHAL. Thank you. Without objection, so ordered. [Dr. Westgate's prepared statement follows:] PAGENO="0238" 234 Supportive Material for Testimony to be given by: Hugh D. Westgate, M.D. on: May 18, 1982 BefoTe: Canmerce, Consumer, and Monetary Affairs Subcommittee of the Committee on Government Operations Chairman - Cong. Benjamin S. Rosenthal House of Representatives - United States Congress - 97th PAGENO="0239" 235 HEALTH CENTER November 27, 1981 Mr. George Beck Hearing Examiner Office of Administrative Hearings Room 300 1745 University Ave. St. Paul, Mn. 55104 Dear Mr. Beck, Enclosed is a statement in support of the regulations in the matter of the proposed adoption of rules of the State Commissioner of Health governing formaldehyde in housing units. This statement is given freely and only out of my interest in the medical affects that I have seen in patients with whom I have been involved. Yours sincerely, Hugh D. Westgate cc: Pauline Bouchard, JD Health Program Representative Division of Environmental Health 717 S.E. Delaware St. Mpls., Mn. 55440 HDW/ls 2525 CHICAGO AVENUE SOUTH * MINNEAPOLIS, MINNESOTA 55404. (612) 874-6122 Members: Abbott-Northwestern Hospital/Sister Kenny Institute Children's Health Center PAGENO="0240" 236 November 27, 1981 INTRODUCTION I apologize for not being able to be present in person since the role of environmental contaminates in diseases of children is of considerable concern to me. I offer this testimony as a second best method of presenting my feelings and data to you. As the past Director of the Department of Anesthesiology and the present Director of Research for the Sudden Infant Death Syndrome Program as well as being Director of the Intensive Care Unit at Childrens Health Center, I feel that I am qualified to offer my thoughts as a physician. My background also includes a Masters Degree in Anesthesiology majoring in respiratory physiology and have been active since 1961 in problems of respiratory diseases. Presently, I am Clinical Assistant Professor at the University of Minnesota and was a full time member or the Department of Anesthesiology at the Universtity from 1961-1970 at which time I helped design and then moved my practice to Childrens Health Center in Minneapolis. STATEMENT Since January of 1979, I have been involved with over 130 families who have had problems with formaldehyde. This involves some 385 people and of those families approximately 30 have moved out of their homes at my suggestion. The symptoms that we have seen have varied from severe asthma in a small child, to severe diarrhea and vomiting in infants to severe respiratory affects with hospitalization in adults and more recently to the onset of undiagnosed convulsions while living in an atmosphere of elevated fromaldehyde coming from chipboard and particle board. In our series of 385 patients, some 63% had sensory problems involving running eyes; 48% had respiratory symptoms; 34% complained or chest pain or burning in the chest; 29% of the people over two years of age had diarrhea and 51% below the age of two had severe diarrbea, 20% of those over two years of age have had nausea and vomiting and 47% of those less than two years of age have had nausea and vomiting. Some 37% have had difficulties with headaches, memory problems, changes in personality and changes in sleep patterns. In January of 1979, an infant died in a mobile home secondary to, I believe, an elevation in formaldehyde. Since that time, we have had four other children who have died in atmospheres in which the formaldehyde was elevated but a cause and effect relationship~ is not well documented. The formaldehyde was .22 parts per million (ppm) in the first infant's room when it died. We have had an elderly couple who bought a mobile home for retirement and who had severe respiratory distress which resluted in hospitalization on two of four exposures to the mobile home. The levels in the mobile home were between .6ppm and 1.2ppm. In another recent case, a two month old premature infant died in a mobile PAGENO="0241" 237 home and a second child, 1½ years old, developed severe vomiting, diarrhea, ear infections and sore throats in that time. This child was hospitalized twice for her symptoms and these cleared without any treatment. While living with the grandparents, she became completely symptom free. A two month old child was brought to stay with them and while in the home developed severe vomiting, diarrhea, a skin rash, watering eyes and lost 12 ounces. All symptoms cleared when this child was returned to a conventional home. The formaldehyde level at that time was O.48ppm. I believe that at the present time there is sufficient evidence to link an environmental factor in mobile homes with human disease. I further feel that evidence is conclusive that formaldehyde vapor given off from building materials utilizing urea-formaldehyde bonding agents is one if not THE cause of symptoms and death in humans particularly in the elderly, the infant, the allergic patient, people with respiratory disease and perhaps in pregnant women. It is evidnet to me that by extrapolating the total vapor concentration breathed by workers during a 40 hour work week the maximum non-occupational exposure limit for formaldehyde should be O.3ppm based on the present OSHA standard or much more reasonably 0.lppm based on the suggested NIOSH standard. Industrial hygienists have indicated that a threshold limit value for non working people should be in the range of 1/10 to 1/100 of any industrial standard. This would make a maximum level, once again based on the suggested NIOSH standard, of O.O1-O.lppm as the maximum concentrations that should be allowed for the consumer. Unfortunately, we have no evidence at the present time of a time dose relationship in man but evidence does exist of changes in lung function in humans chronically exposed to formaldehyde vapors at levels of .13 to 0.8ppm. At the present time, we are also gathering data which is rather frightening in that chronic exposure to formaldehyde, at least on a clinical basis, may show that there is a decrease in brain function when children are exposed to excessive levels over a long period of time. This work is just beginning but there is documentation of one case of a youngster whose IQ decreased by a significant amount and more importantly his memory portion decreased from the 80th percentile to the 13th percentile when exposed to relatively high levels, 0.8ppm, over a long period of time, l½years. Generally there are three ways that a human can respond to any physical, psychological or pathological stress over a prolonged period of time. The first of these is to develop a hypersensitivity to the stress substance, in this case formaldehyde. With this type of response a severe reaction in the child or adult will be produced with extremely low concentrations of the stressing agent. We have seen this with children and adults exposed to formaldehyde and developing severe asthma. This same type of response occurs 97-153 O-82---16 PAGENO="0242" 238 in some individuals who receive penicillin and may actually die from an extremely small dose ofpenicillin whereas most individuals would only be benifited from that dose. The second type of response is an adaptation syndrome whereby the individual upon being exposed to d stress will be able to live in that atmosphere without showing symptoms. The third type of a response is the usual type that one sees whereby individuals will have symptoms that are related tothe amount of stress and these symptoms are reproduce- able when the individual is placed in that stressful circumstance. This is the type of response that we see most commonly in children exposed to formaldehyde vapor in that they will develope their gastrointestinalupsets and respiratory symptoms each time that.they are exposed to the formaldehyde vapor. It is upon this type of response that industrial standards are produced and as I have indicated most industrial hygenists feel that the non occupationalexposure limits should be between 1/10 and 1/100 of any industrial standard. Part of the reason for this is that individuals will absorb a greater amount of the contaminate material because of a longer exposure and breathing more volume. Children are particularly susceptible and small infants even more so because their breathing rate is much faster and their uptake of any contaminate will be much greater for any fixed period of time. Thus an infant exposed to a level of .3ppm will take up a greater volume of formaldehyde than an adult would exposed to the same amount. Therefore I believe that it is quite important that a lower level be established as the standard where children are involved. I as an individual practitioner am convinced of the need for the bill and limits of formaldehyde exposure which you are now considering. I am convinced of its need to the residents of our state both from a medical standpoint and also from a socioeconomic standpoint. I have outlined the reasons for my medical standpoint and have certainly seen a great deal of inconvenience both mental and economic of moving a young family from a mobile home or a home that has been insulated with urea-formaldehyde into a relative'~5 home. The elderly citizen who has worked and saved for retirement and finds that he or she is unable to live in her retirement mobile home or conventional home because of severe respiratory symptoms and also finds that they have no regress as far as recovering their investment also deserves our state's protection and concern. I believe that the bill being considered is an excellent bill with the exception that I feel very strongly that the level that is being set, 0.4ppm, is too high a level for both adults and particularly for the risk group of i:ndividuals, the elderly, the infant, the allergic person or the person with respiratory disease or pregnant women in the first trimester of pernancy. As I have indicated I believe that the maximum concentration that should be *allowed is .3ppm since this is essentially what we have set for occupational exposure and this is based on exposing a group of individuals in the healthiest age group. I truely believe that no PAGENO="0243" 239 infant under the age of 6 months should be exposed to a level of greater than .lppm. If the present suggested standard of .4ppm is accepted then I believe that a special provision should be inserted to protect these risk people. Thank you kindly for reviewing this statement. Yours sincerely, Hugh D. Westgate, M.D. PAGENO="0244" 240 ENVIRONMENTAL O3NTAMINANTS IN MOBILE HOMES: INFANT MORBIDITY AND MONTALIIY Hugh D. Westgate, M.D. Northwestern Pediatric Society Annual Meeting Minneapolis, MN September 28, 1979 - INTRODUCTION As we become mere conscious of energy conservation, our inniediate environ- ment is being changed. Today, I would like to present sane work on how this environmental change may adversely affect the health of some of our patients. On January, 14, 1979, an infant female, birth weight 2.19 kg, 36 weeks gestation was entered into our SIPS surviving twin study group. Her male sibling died three weeks before of SIPS. Our studies showed that the surviving infant, 8 weeks chronologically, showed prolonged apneic periods in light sleep, accentuated with an elevation in room temperature. Periodic breathing also resulted from the elevated temp- erature. Her CD2 response curve showed a cardiac deceleration rather than an increase heart rate. These results were indicative of a child 2-3 weeks pest noninil gestation. On reviewing her brother's death, a history was obtained unlike a history of SIPS but one compatible with an environmental cause. On Dececrber 26 the twins were separated, the larger mere robust male being placed in a previously unused bedroom. The next rnnrning he was found lethargic, ashen and diaphoretic. PAGENO="0245" 241 He was rmanved from, the room and by noon was eating and by evening was normal. He was returned to the bedroom the night of December 27 and at 0830 December 28, tao hours later than his nonzal awakening time, he was found dead and in sweat soaked clothes. Formaldehyde in the rocm was 0.22 parts per million (ppm) with a temperature of 82° compared to a level of 0. lppm and a temperature of 76° in the main bedroom. CO~ and CO levels were normal. An elderly couple anticipating an early retirement bought a mobile home. With C.O.P.D. every time she entered the home severe wheezing and respiratory distress resulted with hospitalization on two of four exposures. Formaldehyde levels varied between O.6ppm and l.2ppm. The family with a recent death of a 2 month premature infant and a 19 month old child had been living in a 1978 mobile bane for 3 months. The infant death occurred after moving into the home and the older child has had three cases of severe vomiting, diarrhea, ear infections, sore throats with lacrirnation in that period of time. Hospitalized twice her symptorrs cleared with no treatment. While living with grandparents, she is also syziptan free. A two month old child while staying with them developed vomiting, diarrhea, a skin rash and watering eyes as well as losing 12 oz. All cleared when returned to a conventional home. Fonneldehyde level was 0.48 ppm. C~NCLUSION As with any enviropmentwl contaminant or disease producing agent, a dose- response relationship and time-dose relationship are sought and one twist then take into account the host resoonse and host affectors including environmental factors. At the present time no absolute dose-response effect for fornri*]!dehyde PAGENO="0246" 242 in humans is proven although specific symptoms at a specific dose have been described, e.g. eye irritation at 0.01-0.05 ppm; odor detections at 0.05 ppm; upper respiratory tract irritation at 0.3-3.0 ppm. Clinical cases however demonstrate a wide variability in symptoms at any particular fonraldehyde level, e.g. possible infant death at 0.22 ppm; severe respiratory effects at 0.6 ppm; eye irritation at 0.03 ppm. Similarly, no time-dose relationship has been proven in man although animal work has darnnstrated such a relationship, e.g. interstitial fibrosis in dog and rat lungs exposed to 3.8 ppm for 90 days (Coon). Such syrsptonw as headache, disturbed sleep, nose and upper respiratory tract irritation, and alteration in pulmonary function studies have been demonstrated in humans chronically exposed to formaldehyde vapor at 0.13-0.8 ppm. We as well as Woodbury have obtained case histories of apparent unexplained abortions in pregnant females living in mobile home. e.g. a Sudden Infant Death Syndrome followed by an abortion. The level of formaldehyde vapor in any environment will be increased by an increase in environmental temperature, by an increase in humidity, and by a decrease in air turnover. Air turnover is controlled in the industrial environment whereas air turnover in a mobile home is minimal. Host response will be very different in an older patient with chronic obstructive lung disease or a teenager with allergic asthma than it will be in a healthy, working, non-emoking female. Response will also be very different in a premature infant with apneic spells secondary to medullary or brainstem irimaturity or hypoxia sustained at birth. In these latter situations the host response will be much sore intense to all concentrations and may be a severe bronchospastic response in the first situation and severe respiratory depression PAGENO="0247" 243 or death in the second situation. Infants may respond to formaldehyde vapor with restlessness, lethargy, vomiting, diarrhea, eye irritation, and increasingly severe respiratory syrnotco's and signs: cough, ~theezing, and nasal stuffiness. We have clinical case histories of deaths occurring in small infants living in mobile homes. No cause and effect relationship of the deaths with formaldehyde vapor can be proven but based on surviving twin respiratory center irmiaturity and the fact that many environmental stress factors produce prolonged apnea, we feel that these babies are at considerable risk to an environmental contaminant such as hydrocarbons, formaldehyde, or fumigants. 1)~cumentation of formaldehyde as a severe irritant of the respiratory system is contained in mach animal experimentation and some human research. Case histories obtained by us and by workers in Wisconsin and Colorado show that even low formaldehyde levels, 0.2 ppm, 0.6 ppm, have a severe effect on patients with chronic obstructive lung disease, asthma and sensitized bronchial smooth muscle. These patients should not be exposed to even minute concentrations of formaldehyde. Formaldehyde has been shown to reduce litter size and increase tho fetal and neonatal death rate in experimental animals~ Some work in Europe has shown a reduced reproductivity along with menstrual irregularities in humans. Once again case histories obtained by us indicate dual abortions and intrauterine deaths in patients living in mobile hcmesetio subsequently when living in a conventional home, bore live, normal infants. It could seem that the pregnant PAGENO="0248" 244 hisnan is at risk particularly during the first trimester of pregancy. It is evident to us that formaldehyde vapor emitted as a result of urea- formaldehyde being used in foam insulation in conventional homes and as part of the bonding agents in chip board, wall coverings, floor board, carpets, etc. comeonly used in mobile homes may adversely affect the health of some people. We therefore feel that the at risk groups that we have defined; infants (partic- ularly prmnature infants), young children, pregnant women (particularly in the first trimetser), the elderly, and any person wtio has a chronic respiratory disease or ~tho has an allergic history or a history of respiratory problems should avoid exposure to formaldehyde vapor. A warning should be issued b~*c manufacturers of and/or dealers of mobile homes as well as insulators using urea-fornuldehyde foam, to potential buyers that formaldehyde vapor in these ci:'mnmtsnces is a ccmnon environmental contaminant and may adversely affect their health. I believe that at the present time there is sufficient evidence to link an environmental factor in mobile homes with human disease. I further feel that evidence is strong that formaldehyde vapor given of f from building materials utilizing urea-formaldehyde bonding agents is one, if not the cause of symptoms and death in humans particularly in the elderly, the infant, the allergic person, the person with respiratory disease and perhaps the pregnant woman. Presently in our country there are no non-occupational exposure standards for formaldehyde. Industrial standards set by OSIIf~. are 3pçm as an average over PAGENO="0249" 245 an 8 hour shift for 5 days a week with a respirator required if the level exceeds lppm in any hour. NIOSH has recczrznended a T.L.V. of lppm the same as West European standards. These standards are set for healthy adult corkers and do not apply to either estromes of age or to normal persons constantly exposed to formaldehyde vapor; e.g. mebile home owners. E~ctrapolating total vapor concentration breathed for a 40 hour week and a 168 hour week the maxlimsn non-occupational exposure limit for formaldehyde should be 0. 3ppo based on the present OSHA standard or 0. lp~sn for the suggested NIOSH standard. In general, I feel that no human should be exposed to home formaldehyde levels greater than 0. 3ppm and that the risk greups particularly the premature infant should not be exposed to levels greater than 0.lppm. This recaneendation is probably not practical but the 0.3pjxn level for all chidren below 6 mentha of age is valid and any infant who shows symptoms relative to his environment should be rmnoved fran that environment. PAGENO="0250" 246 PROBLEM SOURCE 1. ENVIRONMENTAL A. Formaldehyde B. Others - 49 SO2, CO, NO2, Hydrocarbons, Radon, Bacteria, Spores FORMALDEHYDE SOURCE 1. Urea-Formaldehyde Foam Insulation 2. Particleboard 3. Plywood 4. Chipboard 5. Carpet Backing 6. Cooking PAGENO="0251" 247 FORMALDEHYDE EMMI SI ON 1. SOURCE AGE 2. VENTILATION A. H.U.D. - 6/5/76 (<.3-.4 Ch/Hr) B. D.O.E. - 1979-1980 3. ATMOSPHERIC A. Temperature B. Humidity 4. ALTERED HOST RESPONSE A. Infant B. Allergic C. Respiratory Disease PAGENO="0252" 248 1. U.S.A. A. OSHA B. NIOSII 1. U.S.A. NASA 2. DENMARK 3. NETHERLANDS 4. SWEDEN 5. WEST GERMANY 0.1 .ppm* .0.5 ppm* 0.12 ppm* 0.1 ppm* 0.1 ppm* 0.1 ppm* INDUSTRIAL CONTROLS 3 ppm TWA 1 ppm 1 Hour 1 p~nn 30" C. ACGIH 2 ppm T.L.V. 2. DENMARK 1 ppm T.L.V. 3. WEST GERMANY 1 ppm T.L.V. 4. RUSSIA 1 I)P~ T.L.V. INI)OOR AIR CONTROLS- U.S. Navy * inaxiriTlum PAGENO="0253" 249 SYMPTOMS lv? - - 1. SENSORY Eyes 0.01 ppm 63% Odor 0.05 ppm 2. RESPIRATORY 0.03-0.6 ppm Nasal 489 Cough 38% Frequent Colds 32% 3. CHEST PAIN - S.O.B. 34% 4. GASTRO- INTESTINAL Diarrhea > 2 yrs 29~ <2 yrs 51% Nausea-Voiniting~2 yrs 20% 42 yrs 47% 5. HEADACHE 37% 6. SKIN RASH 24% PAGENO="0254" 250 TREATMENT I. Vaispar Sealant 2. Ventilation Increase .i. Caroon Fiiters 4. Ammonia Wash 5. Removal of Risk Group ) 0. 3pcm N=40 M=0.6pprn (O.i-3.lppm) AGENCY INVOLVEMENT HEALTH DEPARTMENT Vince Gary, M.D. 296-5352 Laura Oatrnan 296-5219 ATTORNEY GENERAL Audrey Kaiser-Manka 296-1005 C.P.S.C U.S. 800-638-8326 NAT. ACADEMY OF SCIENCE FORMALDEHYDE INST I TUTE PAGENO="0255" 251 FORMAWE[IYDE WARNING: DRAFT Hugh D. Westgate, M.D. Chidr's Health Center Minneapolis, MN June 25, 1979 PAGENO="0256" 252 FO11~.1ALD1~IYDE 1~'ABNING: DRAFT flTfl~0DUC~ION At the present time there are no non-occupational exposure standards for formaldehyde. The standards set by the Cocurational Safety and Health Admini- stration, 3 p.p.m. (3.5mg/H2) as an average over an 8-hour shift for 5 consecutive working days, are not valid for non-healthy people or for normal persons exposed to formaldehyde vapor constantly, e.g. mobile home ouners. As with any environmental contaminant or disease producing agent, a dose- response relationship and time-dose relationship are sought and one must then take into account the host response and host affectors including environmental factors. At the present time no absolute dose-response effect for formaldehyde in husans is proven although specific symptoms at a specific dose have been described, e.g. eye irritation at 0.01-0.05 p.p.m.; odor detections at 0.05 p.p.m.; upper respiratory tract irritation at 0.3-3.0 p.p.m. Clinical cases however demonstrate a wide variability in symptoms at any particular formaldehyde level, e.g. possible infant death at 0.22 p.p.m.; severe respiratory effects at 0.6 p.p.m.; eye irritation at 0.03 p.p.m. Similarly, no time-dose relationship has been proven in man although animal work has demonstrated such a relationship, e.g. interstitial fibrosis in dog and rat lungs exposed to 3.8 p.p.m. for 90 days (Coon). Such symptoms as headache, disturbed sleep, nose and upper respiratory tract irritation, and alteration in pulmonary function studies have been demonstrated in hurrans chronically exposed to formaldehyde vapor at 0.13-0.8 p.p .m. We as well as Woodbury have obtained case histories of apparent unexplained abortions in pregnant females living in mobile homes, e.g. a Sudden Infant Death Syndrome followed by an abortion. PAGENO="0257" 253 The level of fonnaldehyde vapor in any environment will be increased by an increase in environmental tnmperature, by an increase in hunidity, and by a decrease in air turnover. Air turnover is controlled in the industrial environment whereas air turnover in a mebile home is minimal. Host response will be very different in an older patient with chronic obstruc- tive lung disease or a teenager with allergic asthma than it will be in a healthy, sorking, non-seoking fenale. Response will also be very different in a premature infant with apneic spells secondary to medullary or brainstem irrmaturity or hypoxia sustained at birth. In these latter situations the host response will be much more intense to all concentrations and may be a severe bronchospastic response in the first situation and severe respiratory depression or death in the second situation. 97-153 O-82--17 PAGENO="0258" 254 FORMALDEHYDE WARNING: DRAFf At the present time ue believe that there is sufficient information avail- able to rcsjuire manufacturers of uallboard, particle board and panelling, and mobile home dealerships to uarn consumers about the possibility of medical problems, particularly in a group of at risk people. There is sufficient experimental animal data and an increasing amount of clinical data, with ours and other concerned ~sorkers, to substantiate the above claim. Infants may respond to formaldehyde vapor with restlessness, lethargy, vomiting, diarrhea, eye irritation, and increasingly severe respiratory symptoms and signs; cough, ~theezing, and nasal stuffiness. We have clinical case histories of deaths occurring in aaall infants living in mobile homes. No cause and effect relationship of the deaths with formaldehyde vapor can be proven but based on surviving twin respiratory center inixnturity and the fact that many environmental stress factors produce prolonged apnea, ue feel that these babies are at consider- able risk to an environmental contaminant such as hydrocarbons, formaldehyde, or fumigants. (Appendix A) tkcumentation of formaldehyde as a severe irritant of the respiratory system is contained in much animal experimentation and some human research. Case his- tories obtained by us and by uorkers in Wisconsin and Colorado show that even low formaldehyde levels, 0.2 p.p .m., 0.6 p.p .m., have a severe effect on patients with chronic obstructive lung disease, asthma and sensitized bronchial amooth muscle. These patients should not be exposed to even minute concentrations of formaldehyde. (Appendix 13) PAGENO="0259" 255 Formaldehyde has been shown to reduce litter size and increase the fetal and neonatal death rate in experimental animals. Some work in Europe has shown a reduced reproductivity along with menstrual irregularities in humans. Cbse again case histories obtained by us indicate dual abortions and intrauterine deaths in patients living in mebile homes who subsequently bore live, normal infants. It would seem that the pregnant human is at risk particularly during the first tn- mester of pregnancy. (Appendix C) It is evident to us that formaldehyde vapor emitted as a result of urea- formaldehyde being used in foam insulation in conventional homes and as part of the bonding agents in chip board, vall coverings, floor board, carpets, etc. caamonly used in rrobile homes may adversely affect the health of some people. We therefore feel that the at risk groups that we have defined; infants (particu- larly premature infants), young children, pregnant women (particularly in the first trimester), the elderly, and any person who has a chronic respiratory disease or who has an allergic history or a history of respiratory problems should avoid exposure to formaldehyde vapor. A warning should be issued by manufacturers of and/or dealers o~ mebile homes as well as insulators using urea-formaldehyde foam, to potential buyers that formaldehyde vapor in these circumstances is a ca-anon environmental contaminant and may adversely affect their health. PAGENO="0260" 256 APPEND ICES FORMALDEHYDE TARNING: DRAFT The following four appendices are attached to give examples of case histories obtained from individuals in Minnesota which sub- stantiate the statements made in the description of each risk group. Appendix A are examples of symptoms occurring in infants as well as infant deaths. Appendix B are examples of symptoms occurring in allergic patients as well as in patients with pre- existing respiratory diseases. Appendix C describes examples of individuals living in mobile homes who have had fetal deaths or pregnancy abnormalities. Appendix D are examples of adults and older children having symptoms while living in mobile homes and also in homes that hT~ve been foam insulated. None of these appendices are exhaustive in that they are only examples of case histories that we have. Other case histories are available and each case history is merely a summary of the total history which we have on file. PAGENO="0261" 257 APPENDIX A SYMPTOMS IN INFANTS, INFANT DEATHS 1. Nathan Connery These were premature twins with Nathan dying in a mobile home after being changed to a sleeping room previously unused. There were symptoms of an environmental cause for two days prior to death. The child was found. ashen in color, lethargic, and pro- fusely sweating aftersleeping in the new room. The following day he would not eat in the morning but gradually returned to normal over that day and was place once again in the same room to sleep the second night. The next morning the parents found. him dead, ashen in color,' and surrounded by sweat. The formal- dehyde level was 0.22 p.p.m. in the bedroom and an average level of 0.15 p.p.m. in the remainder of the home. Carbon dioxide and carbon monoxide samples were equal to atmosphere or absent' and the autopsy demonstrated nothing. 2. Joey Ferraro This baby'was a 3 `month old premature" youngster returning to hospital 5 weeks after coming home after a circumcision. He went home from' the hospital fine and died in a mobile home 4 days later. The child. had had symptoms of a respiratory infection. 3. Mr. Pat Sullivan This was a 3month old b'abywho died in a mobile home in November, 197:8. The `mother became pregnant in the home and had a miscarriage in late February,:l979. This mobile `home is presentlybeing tested for formaldehyde. 4. Mr. Gary Parentau, Iron, MN This family had `two babies die of suddeninfant~death October, 1978 while living, in a mobile home. `The autopsies showed no official cause of death. This home is presently being tested for formaldehyde levels. PAGENO="0262" 258 5. Christy Orr Christy was an 8 month old three week premature baby who when brought home developed puffy eyes, watery material coming from her eyes, and chest infections on a number of occasions. During the time that she remained in her mobile hone she had constant colds as did her 6 year old brother, Jason. Christy also had considerable vomiting and spitting up. The adults in the family complained of severe tingling in their nostrils and watering of the eyes. When the youngster was removed from the home and left to live with the grandparents she had no symptoms and when brought into the home on weekends her symptoms recurred. The child has not been in the home since then and the mobile home has been sold. Formaldehyde levels were 0.25 p.p.m. in the living room and 0.21 p.p.m. in the bedroom. This case is in the hands of a lawyer. 6. Mrs. Bunny McKee Within this home are a 3 month old girl, a 2 year old baby, and a 5 year old boy. Also living within this home is a foster daughter who is pregnant and due to be delivered. The 2 year old boy has frequent colds and considerable vomiting. When taken from the mobile home to the grandparents home for a few hours and then coming back to the mobile home, while sleeping at night he suddenly awakens and begins vomiting once again. The 3 month old girl has had constant diarrhea and vomiting for the past 6 days with eyes that looked to be infected because of redness. The child has seen the private physician who has not been able to figure out any cause for this. One of the adults in the family complains of nasal stuffiness, coughing, and considerable lethargy. Mr. and Mrs. McKee complain of headaches and poor sleeping. Formaldehyde levels will be done in this home. 7. David Houston This 11 month old boy was hospitalized on two occasions for severe vomiting which cleared on going into hospital. He has had a number of occasions of severe diarrhea with bouts of diarrhea indicated about once a week. He has had two eye in- fections and a considerable amount of ear infections. His nose is also stuffy and is heard as a noisy sleeper at night. On leaving the mobile home and going to the babysitter's he appears to be fine and sleeps well. Mrs. Houston has had three bouts of bronchitis since moving into the mobile home with no previous history at all. She also has had a number of eye infections and complains of headaches and nasal stuffiness. She also indicates that she feels considerably better at work. PAGENO="0263" 259 8. Mrs. Susan Watson This one year old youngster has had severe bouts of vomiting, diarrhea, and frequent colds. She has become a severe asthmatic, being hospitalized frequently. While in the mobile home Mrs. Watson has complained of headaches, dizziness, and has difficulty in sleeping because of the smell. This family moved out of their home 3 months prior to the time that we contacted them since her private physician had indicated that Billie J0'5 asthma was being stimulated by something in the home. Since moving out of the home, her health has improved considerably. 9. Mrs. Michael Schmidt The history is not yet complete on this patient but the letter from her indicates that their newborn when first brought into their mobile home developed severe respiratory distress and was hospitalized for 10 days. She cleared up and was then taken home and within a couple of days was hospitalized once again because of respiratory distress. Because of these clinical symptoms her physician indicated that she and her daughter should leave the home which they did and lived with her parents for one month; during that one month time her daughter was fine, without symptoms at all. Upon returning home at the end of that month she had runny eyes, some respiratory symptoms but seemed to get along fine after that. This mobile home probably will not be tested. 10. Mr. Rick Carison This family has twins which are now 12 weeks of age and live in a modular home. The twins when brought home were extremely lethargic with abdominal pain, matting of the eyes, and diarrhea, weight loss and sleepiness plus hospitalization for pneumonia. The youngsters were hospitalized where they improved without therapy and then returned home. The symptoms once again recurred and the family then moved out of the home. Their 2 year old child had flu-like symptoms with diarrhea, vomiting, decreased appetite, continuous cold and runny nose while living in the mobile home. This home has been sampled with an initial sample showing 0.03 p.p.m. of formaldehyde. This is an indication of a response to some abnormal environmental factor in the home and formaldehyde levels are being repeated. PAGENO="0264" 260 11. Mr. Gregory Frost, Amery, WI This was a premature infant with constant upper respiratory in- fections, the baby being admitted to hospital because of these. The mobile home was tested and found to have 0.12 p.p.m. The baby was not returned home and moved out and had no subsequent symptoms. 12. Mrs. gichard Christensen This individual lives in a mobile home with a 2 month old son. This child has symptoms of vomiting, diarrhea, running eyes, and respiratory irritation. The formaldehyde level in this home is. 0.5 p.p.m. PAGENO="0265" 261 APPENDIX B SYMPTOMS IN ALLERGIC AND DISEASED PATIENTS 1. Mrs. Edmund Smock This is an older couple who were anticipating early retirement and bought a mobile home. With her chronic obstructive pulmonary disease, every time they enter their mobile home she begins to have severe wheezing and severe respiratory distress. Formalde- hyde levels in this home are 0.60 ppm. and a rescheduling of this is to take place. This is an example of an individual with a respiratory. infection who is severely incapacitated upon being exposed to formaldehyde. 2. Mr. Michael Young This youngster, Kelly, 11 months of age, has developed a severe asthmatic response while living in a mobile home. An older boy, 8 years of age, has also developed asthma since moving into the mobile home. Since Christmas Kelly has been hospitalized three times with severe obstructive lung disease and at the present time is in hospital on a respirator because of her disease. It has been suggested that they not move back into their home and at the present time this is being carried out. Formaldehyde levels are 0.25 ppm. in the living room and 0.21 p.p.m. in the bedroom. A lawyer has been obtained for this family since the cost of moving out of their home is placing a considerable stress on the family. This is an example of an individual with an allergic disease either developing secondary to formaldehyde or being exasperated by formaldehyde. PAGENO="0266" 262 APPENDIX C FETAL DEATHS AND PREGNANCY ABNORMALITIES 1. Mrs. Judy Sprunck While living in a mobile home this individual had two fetal deaths after which the parents moved from their mobile home. During this period of time Mrs. Sprunck had severe bronchitis on two occasions. At the time they moved into their mobile home it was a new home. They moved from their home because of the miscarriages and moved into a conventional home and since that time Mrs. Sprunck has delivered of one normal child and has adopted a second child. 2. Mr. Pat Sullivan These people had a sudden infant death while in their mobile hone in November, 1978. Following this Mrs. Sullivan conceived and had a miscarriage in February, 1979. Mrs. Sullivan had had considerable vomiting, nausea, runny nose, and symptoms of upper respiratory irritations while in the home. Formaldehyde levels are being done but have not been done so far. 3. Mrs. Douglas Lien This family has a 3~ year old and a 1~ year old youngster. Prior to moving from an apartment intro a mobile their elder son had no symptoms and was 10 months of age when moved. He was irritated by the smell upon moving into the mobile home. He had running eyes, upper respiratory signs, and developed rashes which were seen medically but to which a diagnosis was never attached. He has since been diagnosed as a diabetic. The younger son was born while in the mobile home and also was conceived in the mobile home. Upon being brought into the mobile home he was extremely lethargic, would not eat, whereas in the hospital he had been a perfectly normal baby. It was demonstrated that he had an extremely low hemoglobin and he was transfused. This is a new case history and levels will be obtained on this family. PAGENO="0267" 263 APPENDIX D SYMPTOMS IN OLDER CHILDREN AND ADULTS 1. Mrs. James Anderson This individual has had pneumonia on two occasions with bronchitis since moving into a mobile home and never any signs before this. 2. Mrs. Jane Oien This is not a mobile home but is rather a conventional home and these people have contacted Dr. French at the University in the Wood Products Division. It has been suggested that the symptoms of the Oiens are related to the pressed particle board used in the subflooring as well as in some of the panelling. This family consists of two girls, Janelle ~ years and Jodi 6 months of age as well as Mr. and Mrs. Oien. Jodi had severe diarrhea and vomiting for 3-4 weeks after being brought into the mobile home. She is better at the present time but still has the symptoms which dis- appear when she is visiting her grandparents or is away for the weekend. Both youngsters have had ear problems. Janelle wakes up at night with an aching stomach and nauseated as well as headaches and dizziness and has an increased number of coughs and stuffy nose. None of these symptoms are present when the children are away from home. Both adults complain of headaches, lethargy, difficulty in sleeping, chest pain, nasal stuffiness, coughing, and running eyes. Mrs. Oien indicates that when she leaves the home for a weekend her symptoms completely disappear and all return on returning to the home. 3. Miss Ruth Eggum This individual has symptoms related to~ her work and relieved by going into her home. Her work is at a bank and during a period of time when the bank was being built she was at work in a mobile home as a temporary office. She developed a cough, gasping while in the mobile home, chest pain, increase in lethargy, particularly vomiting for the 3 months she was working in the mobile home, all of which stopped on weekends when she was in her home. This individual has kept excellent notes and gives a good history. This mobile home has been moved and samples have not been obtained. PAGENO="0268" 264 4. Mrs. Lois Wobscholl This family consists of Mr. and Mrs. Wobscholl, a girl 8 years of age, and a boy 4 years of age. Upon moving into their mobile home their 4 year old boy developed vomiting and diarrhea over during a three month period of time in late 1978. A cough also developed and he still has spells of vomiting and diarrhea. The family has noticed a strange odor in the home and their 8 year old daughter has become a poor sleeper, developed headaches, and both adults have developed what they claim is an increase in lethargy and headaches since moving into the home. This home was bought from a retired couple who lived there only in the summer and according to neighbors complained constantly of the smell and burning of their eyes. 5. Mr. Robert Thone This is a two year old home in which all of the adults have severe running of their eyes, nasal stuffiness, poor sleep, an increase in headaches, and a marked lethargy if they remain in the home for any length of time. These people have tried a number of times, 13 or 14 times, to live in the home and have stayed there once as long as 3-4 months. However, because people could not come into the home to visit them because of the irritation and because the Thones could not live in the home, they have moved out. Sampling was done on this home and the formaldehyde level was 0.54 p.p.m. These people obtained legal counsel and a settlement out of court for the cost of the home plus medical costs was obtained. 6. Mrs. Marlys Hofkins This mother lives with her 10 year old boy in a mobile home and upon taking up residence in the home the child began to have severe bouts of vomiting in the mornings, developed a hacking, persistent type of cough with marked headaches and sore throat. The father is in the service and when the boy goes to stay with him the cough and vomiting completely disappear, recurring when he returns to the mobile home. Mrs. Hofkins complains of chest pain, poor sleep, lethargy, headaches, nausea and vomiting while she is in the mobile horie. PAGENO="0269" 265 7. Mrs. Sue Theis This is not a mobile home but is a home that has been recently foam insulated. There are 12 and 15 year old youngsters in this home; all of the individuals complain of a sore, raspy throat. The whole family has developed runnimg eyes, cough, nasal stuffi- ness, chest pain, poor sleep, lethargy, severe headaches, nausea in the morning usually without vomiting. These people moved out of their home on August 3 after obtaining testing of their home which indicated a 4.0 p.p.m. formaldehyde level in the master bedroom and 0.8 p.p.m. in the living room. Mrs. Theis has be- come sensitive to formaldehyde and notices reactions when she is around foamed back carpeting and also from other formaldehyde sources. 8. Mr. Leo Gagnon This is a new mobile home; both adults complain of running eyes, constant nasal stuffiness, chest pain, difficulty in sleeping, lethargy, some headaches, and nausea, and Mrs. Gagnon complains of vomiting. These people moved from their mobile home during the summer because it is uninhabitable due to the symptoms that are induced in the adults. They are symptom-free when out of the mobile home. The formaldehyde level~in this home will be measured. 9. Mr. William Roy This is a conventional home with foam insulation. Both husband and wife have numerous complaints and have comtemplated moving from their home but at the present time this is economically impossible. Levels will be measured in this home. 3-23-79 PAGENO="0270" 266 Mr. ROSENTHAL. Dr. Griesemer. Welcome; you may proceed. STATEMENT OF DR. RICHARD A. GRIESEMER, DIRECTOR, BIOL- OGY DIVISION, OAK RIDGE NATIONAL LABORATORY, OAK RIDGE, TENN. Dr. GRIESEMER. Thank you, Mr. Chairman. I have a prepared statement which I would ask be placed in the record. Mr. ROSENTHAL. Without objection, so ordered. Dr. GRIESEMER. I am Richard Griesemer, a research scientist, with doctorate degrees in veterinary medicine and in pathology. I am a diplomate of the specialty board, the American College of Veterinary Pathologists. I think I am representative of the scientif- ic research community for the hearing. The jestimony you heard from the previous witnesses, and in particular from Dr. Westgate, have dealt with the acute effects of formaldehyde and the symptoms in people who have been exposed through no fault of their own to formaldehyde. I would like to make a few comments in addition about the acute effects in the environmental setting and then turn to the more chronic effects and particularly the evidence is that formaldehyde causes cancer. My scientific career has been devoted to research on respiratory diseases, including the effects of formaldehyde, in experimental systems. As a research pathologist, I have been exposed daily, 6 days a week, for more than 25 years to the toxic effects of formaldehyde. So I can speak from experience. Most of the symptoms that have been described thus far also are found in human volunteers who are deliberately exposed to meas- ured amounts of formaldehyde. They include the dryness of the mouth and nose, the excess tear- ing, the blinking of the eyes, the irritation of the eyes, the irrita- tion of the nose and throat. It includes the drowsiness and painful breathing and headaches that have been described. There has also been some loss of ability to smell. All these occur in experimental settings in people as well as obviously in people who are exposed through no fault of their own. Some of the effects that have been described, however, are diffi- cult to attribute to formaldehyde exposure from the available ex- perimental evidence. I have to qualify that because it means in part that not all the experiments that might be done have been done. For example, it is very difficult to relate the long-term nervous effects that have been described this morning to administration of formaldehyde. It may occur, but there are no controlled experiments that would support any long-term effects on the nervous system. I should also add that not much has been said about exposure of the skin and formaldehyde solutions do cause irritation to the skin, much in the same way that the formaldehyde gas causes irritation in the respiratory tract. PAGENO="0271" 267 The acute effects on the respiratory tract are very quick. That is, people exposed to 1 or 2 parts per million of formaldehyde can detect the odor and experience the acute effects immediately. When the solutions are applied to the skin, however, if you were to submerge your hand in a solution of formaldehyde, the effects are delayed because it takes some time and a variable time for the formaldehyde to penetrate far enough into the skin to cause much damage. When it does, the surface layers of the skin slough off, leaving a wrinkled roughened surface. This is painful and it is reddened. Moreover, as you have heard, formaldehyde is a very potent al- lergen for people and for guinea pigs under experimental condi- tions. The skin is one site at which allergic reactions can clearly be demonstrated in people who have had repeated exposures. Formaldehyde is said to be the 10th leading cause of skin reac- tions in patients with dermatitis. About 4 percent of such patients react to skin tests with formaldehyde. In experimental volunteers, about 8 percent develop allergic re- actions to skin exposure. You might find it reasonable to believe that the same sort of allergic reactions could take place through the respiratory system. We have heard of what appear to be hypersensitive people. As yet, there is no experimental evidence that there is, in fact, an immune mediated, hypersensitivity through the respiratory route of exposure. - It has been well stated that there are considerable variations in sensitivity among people and their response to formaldehyde. That is true among animal species, also. It is estimated that somewhere between 10 percent and 20 per- cent of people are much more sensitive to formaldehyde than the rest of us and that they might be able to detect formaldehyde odor in concentrations as low as .01 parts per million. They would have eye sensitization or eye irritation at levels not much different than that. You might expect that people with cardiovascular diseases or chronic pulmonary diseases might be at a higher risk. Again, data are largely lacking. We do know that asthmatics ex- perience a greater degree of irritation when exposed to formalde- hyde. There are some 9 million people with bronchial asthma in this country. There are another 10 million or so with chronic obstructive lung disease and a reasonable estimate is that perhaps 10 percent to 12 percent of the population of this country would experience some degree of hypersensitivity of the upper airways if exposed to form- aldehyde gas. Turning to long-term effects, the major one that should be men- tioned is carcinogenicity. The most definitive study has just been completed and is now available for review. It was conducted by the chemical industry's Institute of Technol- ogy in rats and mice. They exposed large groups of these animals in chambers to controlled environments that contained 2 parts per million, 5.6 parts per million, or 14.3 parts per million of formalde- hyde gas for 6 hours every day, 5 days a week, for 2 years. PAGENO="0272" 268 This is the nature of the experiment along with some control ani- mals that received air without formaldehyde. Nasal cancers developed in the rats at the higher exposure level as early as 15 months after the beginning of the experiment. In both male and female rats, more than 40 percent developed nasal cancers. This is a very significant finding because nasal cancers of any kind are very uncommon. They are rare in rats and mice. The spontaneous incidence is far less than 1 in 1,000. So, 40 per- cent is a very high incidence of a very rare tumor. Moreover, there were some nasal tumors at the middle dose level in rats and at the higher dose level in the mice. It is clear from that study alone that formaldehyde is capable of causing cancer in animals. The CuT study was confirmed by a study at New York Universi- ty in another strain of rats and in which nasal cancers also were found. A related finding which, to my knowledge, has not been made public is that in the study I referred to by the chemical industry's Institute of Technology, benign tumors, or so-called benign tumors, were found in rats exposed to formaldehyde at all three exposure levels, that is, as low as 2 parts per million. The benign tumors were classified as polypoid adenomas and two malignant counterparts of this tumor were found in the high dose group. My analysis of the report is that there is good evidence for car- cinogenicity of formaldehyde at levels as low as 2 parts per million in the rat. What kind of statements can one make about the risk to humans from experiments in animals? One expert committee who reviewed the data was sponsored by the International Agency for Research on Cancer in Lyon, France. They, too, concluded that the evidence is sufficient for the estab- lishment of formaldehyde as a carcinogen for animals. In addition, in the preambles to their monograph series, they state that: "Data that provides sufficient evidence of carcinogenicity in test animals, may be used as an approximate quantitative evaluation of the human risk at the same exposure level." That is, in the absence of any evidence to the contrary, one should assume that might be the case until additional data become available. The effects of formaldehyde in animal `experiments were also evaluated by a panel of Federal scientists, the Federal panel on formaldehyde, which consisted of 16 scientists from 8 Government agencies, including the Consumer Product Safety Commission and the Environmental Protection Agency. That group as well concluded that formaldehyde is a carcinogen for animals and further concluded that it would be prudent to regard formaldehyde as posing a carcinogen risk to humans. There are other kinds of long-term chronic effects that some chemicals pose, such as reproductive disorders or birth defects. Those have not been investigated as yet for formaldehyde. Thank you. [Dr. Griesemer's prepared statement follows:] PAGENO="0273" 269 TESTIMONY PRESENTED TO THE COMMERCE, CONSUMER, AND MONETARY AFFAIRS SUBCOMMITTEE of the COMMITTEE ON GOVERNMENT OPERATIONS May 18, 1982 Washington, D.C. Richard A. Griesemer Director, Biology Division OAK RIDGE NATIONAL LABORATORY* Oak Ridge, Tennessee 37830 operated by Union Carbide Corporation for the Department of Energy *Operated by Union Carbide Corporation under Contract W-74O5-eng-26 with the U.S. Department of Energy. 97153 O-82------18 PAGENO="0274" 270 1. I, Richard A. Griesemer, D.V.M., Ph.D., am presently Director of the Biology Division at the Oak Ridge National Laboratory, Oak Ridge, Tennessee. I received the doctoral degree in veterinary medicine in 1953 from the Ohio State University and the Ph.D. degree in veterinary pathology in 1959 from the same institution. I am a diplomate of the specialty board, the American College of Veterinary Pathologists. 2. My scientific career has been dedicated primarily to research on diseases of the respiratory organs with particular emphasis on cancer. From 1977 to 1980 I was Associate Director of the Division of Cancer Cause and Prevention at the National Cancer Institute and concurrently Deputy Director of the National Toxicology Program where I directed the Federal Government's efforts to identify chemicals that cause cancer. 3. Ny interest in formaldehyde stems in part from my own long-term exposures. In my occupation as a research pathologist I have used formaldehyde extensively to preserve tissues for study under the microscope. I have experienced the acute effects of formaldehyde. 4. The acute toxic effects of human exposure to formaldehyde are well-known and have been reviewed recently by two National Research Council/National Academy of Sciences committees, one commissioned by the Consumer Product Sa~ety Commission (1) and the other by the Environmental Protection Agency (2). Th~ parts of the body predominantly affected are the eye, respiratory tract, an~ skin. Formaldehyde is a colorless gas that is first recognized by its pungent odor. Within seconds after exposure, the irritating effects of the gas on the eyes and nose cause excess tears, reddening of the conjunctiva, blinking of the eyelids, dryness of the nose and throat, and attempts to breathe through the mouth. With continued exposure to the gas, people often experience decreased sense of smell, thirst, painful breathing, headaches, PAGENO="0275" 271 drowsiness and tiredness. The symptoms reported in experimental clinical studies are very much like those described by the Consumer Product Safety Commission for some persons living in houses insulated with urea-formaldehyde foam. 5. Skin exposures are primarily to solutions of formaldehyde in water where formaldehyde is a primary irritant that causes reddening and pain. Formalde- hyde is also a potent allergen in humans and under experimental conditions causes allergic dermatitis in about 8% of healthy volunteers. 6. The amounts of formaldehyde that cause these adverse health effects have been measured in controlled-exposure experiments in healthy human volunteers. In measuring the dose, the length of time of exposure and the concentration of formaldehyde are both important. In general, most of the acute symptoms of formaldehyde toxicity are produced by exposure to 1 to 2 ppm formaldehyde for one minute. Longer exposure (e.g., 30 minutes) may result in increased tolerance to the effects. Eye irritation occurs at concentrations of 0.3 to 1.0 ppm for 5 minutes. It is important to note, however, that there appears to be considerable variation among people in their sensitivity to formaldehyde. Some experience eye irritation when exposed to as low as 0.05 ppm formaldehyde. The available data indicate that perhaps 10 to 20% of humans may be likely to develop symptoms if exposed to concentrations below 1 ppm.. Data are largely lacking on whether certain groups of people, such as children, pregnant women, and the infirm are at greater risk. One might expect persons with chronic respiratory disease or cardiovascular disorders to be at increased risk but controlled studies have not been conducted. Asthma is aggravated by formaldehyde exposure but it is not knwon as yet whether hypersensitivity plays a role in the response. PAGENO="0276" 272 7. The possible health effects from long-term exposure to formaldehyde have been reviewed by the Federal Panel on Formaldehyde (3), which I chaired. The Panel, convened under the auspices of the National Toxicology Program by the Consumer Product Safety Commission, was comprised of 16 scientists from eight federal agencies. From its review of published and unpublished studies, the Panel concluded that definitive experiments exist which demon- strate the mutagenicity and carcinogenicity of formaldehyde under laboratory conditions. Formaldehyde induced both gene mutations and chromosomal aberrations in a variety of test systems. By inhalation, formaldehyde caused cancer of the nose in rats. The concentrations of formaldehyde in inhaled air that caused nasal cancer in Fisher 344 rats are within the same order of magnitude as~those to which humans may be:exposed. Other experimental and human studies on toxic effects, such as teratogenicity and reproductive disorders, are as yet inadequate for a health risk assessment. The Panel further concluded that it is prudent to regard formaldehyde as posing a carcinogenic risk to humans. 8. The carcinogenicity of formaldehyde has also been reviewed by the International Agency for Research on Cancer (4). In its review, an interna- tional committee of scientists concluded that there is sufficient evidence to establish the carcinogenicity of formaldehyde gas for animals but that the evidence from human studies is inadequate as yet. for evaluation. In assessing the relevance of experimental data to the evaluation of carcinogenic risk to humans, the International Agency for Research on Cancer (5) states that in the present state of knowledge, it would be difficult to define a predictable relationship between the dose of a particular chemical required to_produce cancer in test animals and the dose which would produce a similar incidence of PAGENO="0277" 273 cancer in humans. The available data suggest, however, that such a relation- ship may exist, at least for certain classes of carcinogenic chemicals. Data that provide sufficient evidence of carcinogenicity in test animals may there- fore be used in an approximate quantitative evaluation of the human risk at some given exposure level, provided that the nature of the chemical concerned and the physiological, pharmacological and toxicological differences between the test animals and humans are taken into account. However, no acceptable methods are currently available for quantifying the possible errors in such a procedure, whether it is used to generalize between species or to extrapolate from high to low doses. 9. I conclude that formaldehyde gas is a carcinogen and believe it prudent to assume that the doses that are carcinogenic for rats (the only adequately tested animal species) by inhalation are also carcinogenic for humans, until human data to the contrary are obtained. In my review of the most definitive report in rats and mice by the Chemical Industry Institute of Toxicology (6), the evidence for the carcinogenicity of formaldehyde gas for rats at 14.3 ppm is overwhelming, with nasal cancers appearing as early as 15 months after beginning exposure and affecting more than 40% of both male and female rats. Small numbers of nasal cancers also occurred in rats exposed to 5.6 ppm and in mice exposed to 14.1 ppm. Although not emphasized in the Chemical Industry Institute oeToxicology report, there was also a significantly increased incidence of papillary adenomas of the nose in rats exposed to concentrations of formaldehyde as low as 2 ppm. Although the adenomas were interpreted as in a benign stage of development at the time of diagnoses, two examples of the malignant counterpart were reported at a higher dose. Both adenomas and carcinomas of the nose are rare in the strain of rat used (fewer than 1/1000). PAGENO="0278" 274 I believe that they are both related to formaldehyde administration and that all three concentrations tested, 2.0, 5.6, and 14.3 ppm, have been demonstrated to be carcinogenic by inhalation in rats. 10. Formaldehyde may be emitted or released from a variety of consumer products. The majority of formaldehyde is used to make resins, which serve as bonding agents for plywood and particle board and as adhesives for carpets, as examples. Urea-formaldehyde resins add wet strength to paper grocery bags, waxed paper, facial tissues, napkins, paper towels, and disposable sanitary products. Formaldehyde resins may be used on textiles to impart stiffness, wrinkle resistance, and water repellency or to improve adherence of fire retardants or pigments. Among many other uses, formaldehyde may be found in slow-release fertilizers; in pesticides; in leather goods where it is used for tanning; in vaccines, cosmetics and toothpaste where formaldehyde may serve as a preservative or disinfectant; and in nailpolish where it serves as a nail hardener. Some kinds of external exposures are difficult to avoid as formaldehyde occurs in incomplete combustion products of automobiles, stoves, and cigarettes and is a component of photochemical smog. Small amounts of formaldehyde are present naturally in pineapples and apples, too. 11. It is impossible to prevent all exposures to formaldehyde. Formaldehyde is not only widely distributed in nature and in consumer materials but occurs naturally in the body in small amounts as a vital ingredient. It is not toxic in small amounts. To prevent the toxic and carcinogenic effects of formaldehyde, however, it is desirable to avoid adding excessive exposures to those that cannot be avoided. Unfortunately, the available information does not permit precise quantitative recommendations to be made. The studies on acute effects on human volunteers suggest that many healthy people will PAGENO="0279" 275 experience discomfort at air concentrations of approximately 0.3 ppm and above. It is reasonable to assume that those with respiratory or cardio- vascular disorders may be affected at lower concentrations. Some individuals report adverse reactions to shampoos, eye cosmetics, and nail polishes even though the amounts of formaldehyde in these products is very small. The animal carcinogenicity data indicate a significant risk of cancer from prolonged exposure in the range of 1 to 2 ppm. A safety factor of only tenfold would lead to a recommendation that human exposure not exceed 0.1 ppm for extended periods of time. It is clear that attempts should be made to reach the lowest level of exposure that is practicable. 12. More information is needed to assess the possible risks to health from formaldehyde. Ongoing and proposed epidemiologic studies for carcinogenicity should provide useful information in a few years. Needed, too, are human and experimental studies on possible reproductive disorders, inherited effects, and teratogenesis for which few data exist at present. Interactions between formaldehyde and other toxic chemicals have not been investigated. Urgently needed is the development of sensitive and accurate vapor and surface monitors so that individuals can learn for themselves what levels of formaldehyde they and their families are being exposed to in their homes. REFERENCES 1. National Academy of Sciences: Formaldehyde - An Assessment of its Health Effects. Committee on Toxicology, National Academy of Sciences, Washington, D.C., 1980. 2. National Academy of Sciences: Formaldehyde and Other Aldehydes. Committee on Aldehydes. National Academy of Sciences, Washington, D.C., 1981. PAGENO="0280" 276 3. Report of the Federal Panel on Formaldehyde, November, 1980. 4. IARC Nonographs, Supplement 3, 1982, Lyon, in press. 5. IARC Monographs on the Evaluation of the Carcinogenic Risk of Chemicals to Mumans. Vol. 26, pp. 18-19, 1981, Lyon. 6. Final report on a Chronic Inhalation Toxicology Study in Rats and Mice Exposed to Formaldehyde, Chemical Industry Institute of Toxicology, revised December 31, 1981. Mr. ROSENTHAL. Thank you. Mr. Breysse. Welcome; you may proceed. STATEMENT OF PETER BREYSSE, ASSOCIATE PROFESSOR, DE- PARTMENT OF ENVIRONMENTAL HEALTH, SCHOOL OF PUBLIC HEALTH AND COMMUNITY MEDICINE, UNIVERSITY OF WASH- INGTON, SEATTLE, WASH. Mr. BREYSSE. Thank you, Mr. Chairman. I should correct the record. I am not a doctor, neither a Ph. D. nor a M.D. I am an associate professor in the Department of Envi- ronmental Health, School of Public Health and Community Medi- cine, University of Washington in Seattle. I am director of the graduate industrial hygiene Sand safety pro- gram. In addition, we are funded partially through the State indus- trial accident insurance fund at the university and we act as consultants to the WISHA program. I have been doing this kind of work in occupational health and industrial hygiene since 1951, from 1951 to 1963, by contract, and from 1963 to the present time, by legislative enactment. I first became involved in formaldehyde in the late 1950's when I did a survey in a particle board plant and observed workers being exposed to formaldehyde and very shortly after was contacted by a contractor who said: "I just have an apartment house. I have a couple who cannot live in this apartment house. Would you come and see what the prob- lems are." In any event, when we went there, we observed extensive use of particle board, made measurements for formaldehyde which in those days were relatively crude. The couple had to move out. In 1961 I wrote an article dealing with exposure of formaldehyde from particle board and chip board. Since 1975 and 1976 I have been doing extensive surveys in mobile homes, conventional homes, and in other buildings in which people have been exposed to form- aldehyde, the major source being either foam insulation and/or particle board or particle board alone, the two major sources of formaldehyde. In any event, one of the questions that was raised was: What is the susceptibility, of the population, and the National Academy of Sciences in a survey of effects of formaldehyde said that there is no population threshold for irritation effects and no matter how low it gets some people will respond adversely. PAGENO="0281" 277 Recently, in 1980, there was a survey in four schools in Ger- many. Three of the schools had extensive use of formaldehyde pro- ducing materials. Another school was an old school. A questionnaire was sent to these four schools and surveys were done for formaldehyde. The average levels in the three new schools were 0.44 parts per million in school one; 0.57 parts per million in school two; and 0.13 parts per million in school three. There were no detectible levels in the old school. There was increased symptoms, significant statistically, including headaches, dizziness, nausea, irritation of the eyes, nose, and throat, cough, and an increase in the recurrent infections of the upper respiratory tract. When these materials were removed from the three schools, there was a significant decrease in all symptoms, an 89 percent de- crease in dizziness, 86 percent decrease in nausea, and 57 percent decrease in irritation of the throat. The National Institution of Occupational Safety and Health issued a warning on formaldehyde stating that formaldehyde should be considered a cancer risk in humans and reduce occupa- tional levels to the lowest feasible limits. In addition, as I mentioned, we have monitored in over 800 homes in the State of Washington, a few in Oregon, and a few in Idaho. All this monitoring has resulted from complaints of people expe- riencing problems. I broke the data down into mobile homes, into foam insulation, and also into recreation vehicles. I have some other data on 63 other buildings that include apart- ments, classrooms, and the like that essentially involve other than foam insulation. In any event, in 430 mobile homes, 75 percent to 80 percent of the values of formaldehyde were above one-tenth of a part per mil- lion. And, five-eighths of the results ranged from 0.1 to 0.49 parts per million. The people with problems involved 315 adult females, 141 males, and 121 children. The major symptoms were irritation to the eyes, nose, and throat, and 65 percent of the females experienced irritation to the eyes, nose, and throat-55 percent of the males and 45 percent of the children experienced this irritation. As for chronic colds and coughs, 10 percent of the adult females 12 percent of the adult males, and 36 percent of the children-a child being defined as under 18 years of age-experienced chronic colds and cough. Other symptoms of symptoms were chronic headache and chron- ic nausea; 44 percent of the females experienced chronic headaches; 38 percent of the males, and 19 percent of the children. Nausea runs 11 percent females, 6 percent males, and 4 percent children. Approximately 30 percent of the adults complained either of memory lapse or drowsiness. Some people describe it as periods of memory lapse, other persons describe it as periods of drowsiness. We evaluated 244 homes with urea formaldehyde foam insula- tion. It is interesting to note that the average level of formaldehyde PAGENO="0282" 278 in the mobile homes with particle board were anywhere from two to five times higher than the levels of formaldehyde with foam in- sulation. With foam insulation, the majority of the levels, over half were one-tenth of a part per million and below, whereas with mobile homes, the reverse was true. The majority of the results were above a tenth of a part per million. In any event, as you look at the statistics and the effects, you find the same thing occurring of 55 percent eyes, nose, and throat and respiratory tract irritation for females, males, and about 40 percent for children. The same for headaches and nausea. It is also interesting to note about 10 percent of the people experienced skin rash. Whether this is direct contact with the skin, at least for particle board, or whether the vapors can cause the problems or whether there are other aldehydes that cause the skin problems, we do not know. The same thing occurred in recreational vehicles which were built primarily with particle board. We had no level below one- tenth of a part per million. All the levels were one-tenth of a part of a million and above in the 14 units with one of the units result- ing in levels above one part per million. The symptoms, once again, correspond to the previous reports, al- though obviously the numbers were smaller-8 females, 11 males, and 1 child. The major source in the mobile home is obviously particle board. You will be visiting that mobile home. All the floors are particle board. You probably will not be able to see that. Mr. ROSENTHAL. Is there any risk in just a quick walk through? Mr. BREYSSE. It depends on how sensitive you are. Some people respond very rapidly. If you open all the windows and doors and keep the air moving, I suppose the risk would be minimized. I also would like to, as part of the information I have given you, include an article on particle board from the proceedings of the fifth Washington State University symposium on particle board. This was in 1971. The title of the article is "Advances in Detect- ing Formaldehyde Release." The industry has known that particle board has released formal- dehyde for many years. In addition, I have a letter from a dealer, after reading one of the articles that we have written in November 1978, which I have given you, said: I read with interest a recent article in the National Enquirer in which you were quoted. As a mobile home dealer for the past 25 years, I can fully agree with you and other points brought out in the article. I can cite numerous cases where my customers have had serious problems with formaldehyde fumes causing physical discomforts. In some cases the people simply had to move out of their homes. There is other information I provided. The irony of the foam in- sulation problem cases is this. In most cases the insulation is no good because it shrinks and it is full of voids. In every situation where I have been involved where the foam has been removed and * where people have had it removed, all have spoken of considerable shrinkage and voids. PAGENO="0283" 279 So, it is not much good as insulation. In a few homes that we have been in where we cannot find any source of formaldehyde, the levels usually are under one-hundredth of a part per million, 0.01. What obviously needs to be done is this. There is no doubt in my mind that particle board is probably the most single important source of formaldehyde. I do not see much other choice except to ban that. If you are going to ban foam insulation-and we have a com- pound that produces two to five times more formaldehyde-I think that particle board that is made with urea formaldehyde resin ought to be banned also. In addition, we have found significant levels of formaldehyde in new conventional homes that have been built tight and using a lot of particle board. So it is not only a mobile home or a manufactured home situa- tion. If you build a home tight and you use a lot of particle board, the problem is right there as welL As I say, as a major source it does not appear practical to set an air standard. I am not sure how you enforce that and to set a prod- uct standard, I think may be even more difficult. Thank you. I would ask that my prepared statement and the enclosures be made a part of the record. Mr. ROSENTHAL. Thank you. Without objection, so ordered. [Mr. Breysse's prepared statement follows:] PAGENO="0284" 280 PREPARED STATEMENT OF PETER BREYSSE, ASSOCIATE PROFESSOR DEPARTMENT OF ENVIRONMENTAL HEALTH ~SCHOOL OFPUBLIC HEALTH AND COMMUNITY MEDICINE UNIVERSITY OF WASHINGTON SEATTLE, WASHINGTON MAY 18, 1982 PAGENO="0285" * 281 FfIR~AJ.\L11E14'(IIE - A~ A~9E5~M~T ~F 1T~~4~TH ~rrr~ ~`II\TUThJAL A~ABEMY S1~ 5E~4UE~ , WAS~1. I~.E.) MAL 1~1i~i11 [EU'~[LU5fflN5 . * . .. . 1. WIl 1~ll1k1Li\T1ll1'I 11~R5I-1[ftII FII~ 1Ri~ATAT1II~\ ~E~1J ~. F MA1..IIEWTh~ 1~E KEPT AT LII~J~%T ~1~AUftAL * LEV[L 1~1 I IIUR A~ * * F~ FIIRT~ER ~ * .? A. WI\5A1.. [AN[R PIITE~'1T1A~ IM UII~I~A~5 *~b* k[PRll~ll[T1VE - TEQItTIIIIft!ff ~FfT~T [. 5ti5[EPTft~L1T'i'~ ELEERI.N- I~FA~T~ IL ~55I~1L111 1ff. 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F~tllW ~ ~~AJTHT~5 FUft~J\N~ P1 MII\I1\~1. ~1F [fi k~\ilMJ~EI~iYII E ~i~T PAGENO="0287" 283 ___ ~ ___ GR~ ~ .71: Til i~ 4 nX ft~UP IIU~ PAGENO="0288" 284 t~1GN~ ~U~L Tfl~Th~ ~[REA~fl~ 5~MPTt~A5 ~1~1F~NT AT ll~ffl5 ~E~[ftE I1lUU~iE55 1TAT1~ ~YE5 :1 R~UJR~MT 1~FE~Tffl~1~: ll~ II P ER RE5P t ~ TRA{T PAGENO="0289" 285 5~fffflt~ ~TUTh~' E~E5t1LT~ M~iIJ'(]1E [IIML ~M ~EW 5114IIIIL~ T~ ~i ~44~ ~a ~1 T~ ~ ll~ ~ ~ 97-153 O-82----19 PAGENO="0290" 286 LULUbM~ ~1~UU~ ~U'~ ~E5II~T5 FllW1~~~P 5~\fltA~T ~9~1~iE ll'~ AU~ ~IYM~TUM~ EX~ ~ ~iI~ ~1!~\15EA IRT4JI\71 ~ PAGENO="0291" 287 FRMj~LmEi4'(llE - A~ A~9E5~MD~T ~F 1T9 ~4LTfl FJT~[Th MAT1fl~'JJ~L AtABEMY t~F ~t1E~CE~ , W~4E~4L]tL) ~ t~fl~l1I :1. NIh ~`1JL~TIIIW 11~R[~P[!L~ ~ ~ 1fl~MA~ll~W1]~ 1~1h KEPT AT L~'IE5T P~AUI[hI1L LEVEL I~1 I~IIflR AIR I N~{~ Fll~ FIIRT~R RE5EA~[~ A. WA5AI.. [AN[R PIIT[~TtI\1. IM UA~I5 REPRll~ll[JIVE - TE~AT~L-[~I[ ~FfE[T [, 5IJ5[EPTftI~L1T'( EIJIERIY 1~FAMT~ IL PthN51~1L1T'( 1ff 1~TER4[fl~ W~ llT~[R ~1R LLIITA~T~ PAGENO="0292" 288 FORMALDEHYDE: EVIDENCE OF CARCINOGENICITY 0 It H-C-H U.S. DEPARTMENT O~ HEALTH AND HUMAN SERVICES * PUblic Health Service 4 - Centers for Disease Control f71J~~ -.-i - National Institute for Occupational Safety and Health - 6~eae `ktd&9eaCe AP~L15~981 PAGENO="0293" 289 H flIP%RENT 1NTELU1~HtE ~`H-UTIW 31 ~cuzu. ~ FMUIY~[ EV1~EN[E IIF [MI[IMIIIENL[I1Y 1'1ll EX1~Eli1JRE (~ P1~t~( ~fl ~AT5 VE~E'E~ ~EJ(M1~(IIII5 [EU. [M~[L~A5 ~ WA~4~ TIIR~IW~T[~ - ~L5~ ~ ~ I~IAT5 ~[VELllI'E~ k[~JI1fflATII~X [PIT~[UAL [A1!~[(t~MMA5 ~ RATS - PP~ ~tJ[1AMllU5 [ELI ~ [At~1[ER [III ~T[IIIIY PAGENO="0294" 290 }~ t1ittR~NT ~4TtLLU~E&jtt v~ua~Ttfl ~4- t'~YU ~TIIhI1Y II~T. 19, 19P~1 Iffli RAT - F M~[II[~Y~[ ~ = B[ME I4.b~'PM ~ t~Pl]5~k[.-. ~ I111'( ~ 1~R5/~A? EVER ~14 I[AY~: .RE~ULT5 ~Ei RATh - ~1J~4M1IEJ~ [ftLI NA~AL [At~~[~ *LA~[ER ~LLAR 111 [1 II ~T~11Y PAGENO="0295" 291 I~i1II15I-J. [EJRR~T I~1TLU1~IEMtE ~iULI.ET1~4 ~4 FIIR~AL~E(IY~E 5l~ffitiE.]I TM~ [1~Iff1StJ19ET1 A [AW[Eft ~15K Til ~[D~M&~ REIIIU[ ~[1U1ATI~NAL [XPII5I]RE~ T~ TJIE UItk1[5Tf[A5I~LE LUMf~ PAGENO="0296" ~U~LE ~ F1~1IE [~L *PI1~ f4~U ut~~t1~. KtT[~EN TIIT~L ~ ~ 9 141 99/9% Resp. .00169 1.96 97.5% Wong Chemical All Ca. 2026 .0182 2.94 99.8% workers Reap. - .0059 1.09 86% Conclusion: Increased risk of Ca. overall, reap. Ca. would be detected by present studies. Clearly because of low incidence of nasal Ca., (6 cases in Canada last year), much larger samples required. But absolute risk is apparently very low, since no cases reported in any of these studies, and others. And formaldehyde not implicated in case/control studies (See paper by Barnes). PAGENO="0388" 384 (2) Gibson - CuT (Chemical Industry Institute of Technology). Further analysis of animal studies. Why did rats get nasal Ca. and mice did not? (a) Analysis of anatomical structures. Rat Mouse Volume FM/mm o~fl4 0.012 Surface area 13.4 2.9 Dose/mm/cm3 0.15 0.076 *. Rats receive 2 x dose/surface area as mice. (b) Mutagenicity of FM is weak or not at all. Why then did Ca. develop, in only 15 ppm rats? Cell proliferation (based on C'4 tracing I think) Rats Control 0.22 0.5 ppm 0.38 2 ppm 0.33 6 15 - Fewer~ cells because great damage Cc) Histology shows massive ulceration, surface damage, from irritant prope~ties at high levels. (d) Is it reversible? Withdraw FM exposure and within 3 months - 50% of rats have no dysplasia - 100% of rats have no metaplasia. Conclusion: Massive cell damage leads to cell proliferation, leading ultimately to metaplasia. PAGENO="0389" 385 LOW DOSE extrapolation. Dependent on model used, dose for risk of 1/100,000 Ca. range from 2.3 ppm to 0.005 ppm. CPSC upper limit (51/million) e.g. 1/4% of all human Ca. in UFFI homes due to UFFI. based on time averaged dose, e.g. 20 ppm for 1 hour ~ 1 ppm for 20 hours. which fr~ further analysis of animal studies is clearly inappropriate! Mr. ROSENTHAL. Dr. Higginson. STATEMENT OF JOHN HIGGINSON, M.D., SENIOR SCIENTIST, UNI- VERSITIES ASSOCIATED FOR RESEARCH AND EDUCATION IN PATHOLOGY, INC. Dr. HIGGIN50N. Mr. Chairman, my name is John Higginson, M.D. At present, I am senior scientist at the Universities Associated for Research and Education in Pathology. It is a consortium of 15 American universities, whose task is to utilize a wide academic base to execute a broad program on environmental health. Previously, I retired from being the director of the International Agency for Research in Cancer, which is an autonomous organiza- tion supported by 12 governments, including the United States. The objective of the agency is to generate and evaluate data on the causation of human cancer, especially in relationship to the envi- ronment. I have been requested to attend these hearings as an independ- ent scientific witness and to comment on the potentially adverse health effects of formaldehyde and the generic scientific issues in- volved, especially as they relate to cancer. I, myself, have not worked on the carcinogenic effects of formal- dehyde nor on nasopharyngeal cancer, which is another cancer at- tributed to formaldehyde since the mid-1960's. However, I have been actively engaged in the administration of the scientific pro- grams of the IARC and therefore have some familiarity with the generic issues involved as well as with the literature. In the early days, the IARC established a program which pre- pared a series of monographs to evaluate chemicals and occupa- tions and their potential cancer risks for humans. This program was placed under the leadership of Dr. Tomatis, who has done a superb job. It is now recognized as the foremost program of its type in the world. The monographs are utilized by many national gov- ernments for regulation and other purposes. A monograph is to be published on formaldehyde. As a pathologist, the subject of formaldehyde has been of great personal interest to me, as to all pathologists have been in the past PAGENO="0390" 386 exposed to high levels of this gas, in my case, for 25 years. All are aware of the unpleasant side effects which high concentrations may produce, especially in sensitive individuals. As the time is growing late, sir, I intend to shorten my comments to avoid unnecessary duplication of what has been said by previous speakers yesterday and today. I will not further address myself to the discomfort caused by formaldehyde products because they have been dealt with by Dr. Newhouse, but rather with the possibility that formaldehyde presents a potential cancer risk to man. When it was first* reported that it could produce nasal cancer in rats it was a totally unexpected result. Naturally, it gave rise to concern. I am quite content that the animal data, as to carcinogen- icity, can be accepted unequivocally. While it is accepted that it is not necessary that the organs in man in which cancer may appear is the same as those in the rodent, in this case the pertinent organ in man is the same as that which was exposed in the rodent, and one might anticipate cases of nasal cancer if it was a human carcinogen. Therefore, one has given particular attention to the nose, the nasopharynx-that is the back of the nose-and to the lung. The first IARC group attempting to evaluate the data had to delay because the data had not been fully published on the rat. However, at the second meeting which was held in the fall of last year, it concluded that there is sufficient evidence of the carcino- genicity of formaldehyde gas in rats. According to the agency's traditional evaluation, when a sub- stance has been demonstrated to be carcinogenic in animals, the* workshop of experts reports the possibility that such a substance~ may carry a potential risk for humans, especially in the absence of adequate epidemiological data to the contrary. In practice, this phraseology could apply to a situation where the risk is consider- able to one where the risk is almost zero. The complexities of extrapolation of potencies from animals to man are well known. I do not want to repeat them. However, this is summarized in the preamble of the agency's monograph which states: "No adequate criteria are presently available to interpret experimental carcinogenicity data directly to terms of carcinogenic potential for humans." Today, few experienced oncologists attempt to extrapolate straight mathematical numbers without considering other modify- ing factors which may involve such extrapolation based on modern theories of carcinogenesis. This is different from the past, when one made simpler evaluations. Thus, one is thrown back on the epidemiological data. There are quite a number of studies. Unfortunately, a number of them are not yet published. They are in press, or we know about them through the old boy network, and they will probably be published within the next 18 months or so. They are studies specifically relat- ed to the role of formaldehyde and the effect of exposure. Some of the studies in the past have been poor from a technologi- cal point of view in demonstrating a positive risk, but they may be good evidence of the absence of a risk. Some studies have shown irregular results, such as the increase of certain cancers in the brain, prostate, kidney, et cetera. These small increases are not PAGENO="0391" 387 consistent between studies, and probably are artifacts based on small numbers. I do not think, they are meaningful in the present case. I should, however, emphasize that the studies which we do have on people who were occupationally exposed-pathologists, labora- tory technicians, and so on-have not shown any increased risk of nasal cancer, cancer of the nasopharynx, or of the lung. In addi- tion, however, one can deduce a great deal more by looking at the circumstantial epidemiological data which are available. The use of circumstantial epidemiological data requires some degree of biological knowledge, experience, and flexibility by epide- miologists. However, many people believe that, when you have a situation based only on animal positivity, the data at least should be taken into consideration by national bodies in attempting an overall evaluation of regulatory policy. Such data were used in evaluating the role of saccharine and DDT, in humans for example. In the case of formaldehyde, the type of cancer believed likely to occur, that is, of the nose, is easy to diagnose. The chemical has been used on a large scale for a number of years. One would expect it to show up within certain statistical limits which I will not dis- cuss. Other circumstantial data relate, for example, to the wood indus- try, where there have been. extensive studies on the risk of nasal cancer in the occupation. These data have been well confirmed in a number of studies. There is an increase in nose cancer in such oc- cupations, but it is related to hard wood dust and not, apparently, to the formaldehyde part of the industry. Similarly, pathologists have been studing a number of areas, and again no increase was found in the United Kingdom or in Den- mark. In nearly all countries, irrespective of their degree of indus- trial development, the incidence of nasal cancer is surprisingly con- stant. In a number of developed countries where formaldehyde has been widely used, the risk of nasal cancer is, possibly, falling. Thus, to conclude this portion which is my evaluation of the data, I would say that all the data taken together, as a whole, pro- vide no evidence of any cancer hazard. However, they are still limited and insufficient to exclude a minimal risk. They do weigh heavily, however, against the view that formaldehyde gas constitutes any considerable additional risk of nasal cancer for humans at the levels at which they have been exposed in the past. I have discussed these conclusions with a number of distin- guished epidemiologists, including Sir Richard Doll, the dozen of occupational epidemiologists, and they are in general agreement. I should point out before terminating that, in the past, we have been struck by the failure to find nasal cancer in man more fre- quently in view of the numerous noxious gasses to which he is ex- posed, such as smoking, et cetera. In fact, dusts seem more impor- tant. It is interesting that certain recent rodent studies of formalde- hyde suggest mechanist explanations based on the biology of the le- sions which may explain such discrepancies. I believe, in conclusion, that if the above evaluation for those ex- posed at high levels is accepted, it is improbable that there is a sig- PAGENO="0392" 388 nificant risk to those exposed at much lower levels. Nonetheless, I do believe that it would be advantageous to follow higher risk groups to satisfy the uncertainties. I hope these comments may be of some value to the deliberations of the committee. Thank you. [Dr. Higginson's prepared statement follows:] PAGENO="0393" 389 Statement to Congressional Hearing by Dr. J. Higginson, M.D. Wednesday, May 19, 1982 My name is John Higginson, M.D.. At present, I am Senior Scientist to Universities Associated for Research and Education in Pathology. This is a consortium of 15 U.S. Universities, where my task is to utilize this extensive academic base to develop and execute broad programs on environmental factors in health and disease. I am also Research Professor in Pathology and Epidemiology at the University of North Carolina, Chapel Hill. Previously, I was Director of the International Agency for Research on Cancer (IARC) in Lyon, France. This is an autonomous organization within the World Health Organization supported by 12 governments, including the United States. The IARC's objective is to generate and evaluate data on the causation of human cancer, especially in relation to the environment. The conclusions of its workshops are published and are made available to all participating states and appropriate authorities around the world. I have been requested by Mr. Hiler to attend these hearings as an independent expert witness and to comment on the potential adverse health effects of formaldehyde, notably cancer. I myself have not worked on the carcinogenic effects of formaldehyde, nor on nasopharyngeal cancer since the mid-sixties. However, I have been actively engaged in the administration of the scientific programs of the IARC, and therefore have some familiarity with the issues involved as well as the literature. In the early days of the IARC, I set up a program for the evaluation of potential carcinogenic risks of chemicals and occupations to man under the guidance of Dr. Lorenzo Tomatis. Dr. Tomatis did a superb job and this program is now recognized as the foremost program of its type in the world. The monographs are utilized by many national governments for regulatory and other purposes. The objectives of the monographs are to evaluate the scientific data, improve evaluation and develop new technology in so doing. The agency at the desire of the Governing Council is not engaged in evaluating parascientific and socio-econotnic issues or risk/benefit analysis. A monograph to be published shortly deals with formaldehyde. As a pathologist, the subject of formaldehyde is of great interest to me, as all pathologists have been exposed to high levels of the gas often for considerable periods in their careers, in my case for approximately 25 years. All have been aware of the unpleasant irritating side effects that exposures to formaldehyde may produce especially in sensitive individuals. Concern regarding formaldehyde, however, has only arisen in the public domain recently for two reasons. Firstly, universal use of urea formaldehyde products in insulating houses, especially following the energy crisis in Canada. The increased sealing of houses has caused increased levels of gas in conventional and mobile homes, both from insulation and possibly equally important from manufactured wood products, e.g. fiber board, etc. There appears to be no doubt that, especially in Canada, sufficient reports have arisen of discomfort caused by the interior formaldehyde levels as to give concern to possible health effects. The data are somewhat unsatisfactory due to lack of controls, however, studies from other parts of the world are also not confirmed. I do not intend to address myself further to this aspect. The second reason for concern arose due to the induction of nasal tumors in rats following exposure to high levels of the gas. This was a totally unexpected result, especially as formaldehyde had been around a long time and widely used by certain members of the scientific community without any evidence of carcinogenicity. This finding naturally gave rise to considerable concern as to the importance of formaldehyde as a pollutant in the home environment. PAGENO="0394" 390 I am quite content to accept that the animal data indicate carcinogenicity in rodents and therefore by definition formaldehyde gas constitutes a potential human risk. I also accept that it does not necessarily follow that the pertinent organ in man is the same as in the susceptible animal, even when the role of exposures is the same. In this case, however, the experimental tumor appears in the organ directly irritated by the gas, and the same organs are also obviously irritated in man, i.e. the nose and nasopharynx. The first IARC group that reviewed that data did not consider that the animal data was "sufficient" to determine the carcinogenicity of formaldehyde gas in rats. However, the report of this meeting was delayed until further information became available from the Chemical Indlistries Institute of Toxicology, at which time the second draft concluded, "there is sufficient evidence for the carcinogenicity of formaldehyde gas in rats". According to the agency's traditional evaluation where a substance has been demonstrated to be carcinogenic in animals, the agency has reported the possibility that such a substance may "for practical purposes" carry a potential risk for humans, "in the absence of adequate epidemiological data to the contrary". In practice, the risk to humans could range from practically zero to being very considerable and the same phraseology could be used in the evaluation. In the case of formaldehyde, the working group concluded that the epidemiological data in humans were inadequate for evaluation. The complexities of extrapolation of potency from animals to man are briefly described in the preamble of the IARC monographs and no working party during my directorship ever stated that such an extrapolation could be made routinely with any degree of credibility. In fact, the first sentence in the preamble states, "No adequate criteria are presently available to interpret experimental carcinogenicity data directly in terms of carcinogenic potential for humans." However, possible methods of doing so are discussed, but to date, I am unaware that any universally acceptable scientific method has yet been developed for any known chemical cancer-inducing agents. Few experienced experimental oncologists would make any attempt to extrapolate mathematically the exact degree of added risk to humans from animal data, without considering the many parameters involved. Such attempts were fashionable among biostaticians in the early 70s when the complexities inherent in modern theories of carcinogeneais were not appreciated. In the present situation, much of the disagreement regarding formaldehyde carcinogenicity depends on evaulation of the epidemiological data and what constitutes adequate epidemiological data. Thus, there tends to be a difference of opinion between epidemiologists and experimentalists as to the relative importance of the human data. Both are agreed, however, that neither human nor animal data can prove the negative, i.e. absence of risk, hence the problem. The epidemiological data are of two types. First a number of specific analytical studies and secondly circumstantial and descriptive data. Thusfar, no published data indicates that increases in nasal or lung cancers have occurred in any study due to formaldehyde exposure. The design of some of these studies is extremely poor in demonstrating a positive risk, but provide good evidence for the absence of a risk, i.e. no case has in fact occurred. In a certain number of studies, irregular results of increases of certain cancers have been reported, i.e. brain, kidney, etc. These are almost certainly statistical artifacts as they are based on small numbers and are not consistent. Furthermore, it is common experience that where total cancer is PAGENO="0395" 391 divided into many subsites, a few individual sites will show significant increases or decreases by chance. Personally, I do not think that these irregular small changes in cancer at different sites are meaningful in the formaldehyde studies as they are not consistent. - The latest draft ot the IARC monograph reviews the results of three epidemiology studies which it was concluded provide inadequate evidence to assess the carcinogenicity of formaldehyde in man. In the past, the agency's monographs have tended only to discuss specific published analytical studies and avoided evaluation of circumstantial epidemiological and biological data. The latter may be considerable but requires considerable biological knowledge, intelligence and flexibility by very experienced epidemiologists for interpre- tation. Many epidemiologists, however, believe that such data should at least be taken into consideration by national bodies when making an overall evaluation. The use of such data has played a major role in evaluating saccharin and DDT. In this case, the type of cancer one might believe to be produced by formaldehyde gas is normally rare. Any marked excess should be easy to recog- nize in view of the large scale on which the chemical has been used for many years. Whereas proportional mortality rates from cancer are poor in terms of positive evidence of an occupational risk, because an increased proportion of a cancer may occur as a result of reduced mortality from other causes due some- times to the "healthy worker effect" they may provide excellent evidence as to the absence of a risk if the proportion of death due to a particular type of cancer is low. In the wood industry, there have been extensive studies regarding the increase in the risk of nasal cancer which occurs in this occupation. However, the data shows that the increase is most likely to occur in those segments associated with certain hardwood dusts. It has not been reported in those portions of the wood industry where formaldehyde is most likely to be used. The extensive studies on occupational mortality in the United Kingdom show no significant increases in nasal cancer , except in butchers. Again, these data are not conclusive. However, it is more important to note that studies on those members of the medical profession likely to be exposed to high levels of formaldehyde in the United Kingdom and Denmark, e.g. pathologists, show no increase in nasal and other cancers that could be attributed to formaldehyde. In nearly all countries, irrespective of their degree of industrial develop- ment, the incidence of nasal cancer is surprisingly constant and in a number of developed countries where formaldehyde has been widely used, the risk of nasal cancer appears to be falling. I am also aware through the old boy network of some additional analytical studies to be published. These are also negative. Isolated cases of nasal cancer and formaldehyde exposure do not stand up to epidemiological analysis. In conclusion, all these data taken together provide no positive evidence of any cancer hazard at all. Although they are still limited and insufficient to exclude a minimal risk, I believe they weigh heavily against the view that formaldehyde gas constitutes any substantial risk for nasal cancer or other tumors to humans at the levels at which humans have been exposed. Obviously, I believe that it would be advantageous to continue follow-up on occupational groups exposed to high levels of formaldehyde which would provide more useful evidence as to the validity of these conclusions. I have discussed the known epidemiological evidence with a number of distinguished epidemiologists, including Sir Richard Doll, the doyen of all PAGENO="0396" 392 epidemiologists in the occupational field, and have been in general accord with the above evaluations. If the above evaluation for those exposed to high levels is accepted, it is highly improbable that added significant cancer risk would occur in those exposed to much lower levels. I should point out that for a long time oncologists have been puzzled by the failure of humans to develop more nasal and sinus cancer despite the fact that man is exposed to many noxious gases, e.g. smoking. Dusts seem more important. It is of interest however that recent rodent studies on formaldehyde provide biological observations which may explain such discrepancies. Studies of formaldehyde carcinogenesis in animals raise interesting general scientific issues which require more detailed research as to mechanism and the significance of formaldehyde levels which are normally present in the tissues and which raise interesting scientific issues. I h\ope these comments may be of some value to the deliberations of this committee. Mr. ROSENTHAL. Thank you very much. Dr. Valdes-Dapena? STATEMENT OF MARIE VALDES-DAPENA, M.D., PROFESSOR OF PEDIATRICS AND PATHOLOGY, UNIVERSITY OF MIAMI SCHOOL OF MEDICINE Dr. VALDES-DAPENA. Thank you, Mr. Chairman. I do not have a prepared statement but have come to answer any relevant ques- tions. Mr. ROSENTHAL. Mr. Hiler? Mr. HILER. Thank you, Mr. Chairman. Dr. Dapena, we appreciate that you have had a long-standing professional interest in the problem of sudden-infant-death syn- drome. In testimony we received yesterday, `the argument was made that there appeared to be, or might be, a positive correlation between sudden-infant-death syndrome and exposure to formalde- hyde. Have you found any evidence to support that proposition? Dr. VALDES-DAPENA. There are to date no data which would sup- port that contention. The sudden-infant-death syndrome undoubtedly occurs more fre- quently among those people who are socially and economically de- prived. This tendency has been noted all over the world. Therefore, one might encounter a certain number of cases among people who live in mobile homes, who are not the most affluent people. That would be expected. No systematic study of the subject has been done. Mr. HILER. There has been no study conducted, or no authorita- tive study, consistent with scientific analysis. Dr. VALDES-DAPENA. That is exactly right. Mr. HILER. How long have you been interested in this subject? Dr. VALDES-DAPENA. I began working in that sphere of research in 1959. I believe that is 23 years ago. Mr. HILER. You have been working in this area for 23 years on sudden-infant-death syndrome. Dr. VALDES-DAPENA. Yes. I have worked for 23 years in the pa- thology and epidemiology of the sudden-infant-death syndrome. PAGENO="0397" 393 Mr. HILER. You have encountered absolutely no study or scientif- ic analysis which links in any way, shape, or form to sudden-infant- death syndrome with formaldehyde. Dr. VALDES-DAPENA. Having been responsible recently for a couple of formal reviews of the literature, both for the Federal Gov- ernment and for pediatric journals, I can attest to the fact that no such data exist. Mr. HILER. Is there any investigative work currently being done in this area? Dr. VALDES-DAPENA. There is a large epidemiological project going on right now, which was initiated by and managed by the National Institute of Child Health and Human Development. Un- fortunately, this particular question will not be answered by that study. Mr. HILER. What kind of work do you believe needs to be done to try and identify the causes of sudden-infant-death syndrome? Dr. VALDES-DAPENA. Much has already been accomplished in that regard. A 1~t of work is going on right now all over the world. Most people do not consider that the syndrome is one phenomenon but rather that a heterogeneous group of causes which will gradu- ally unfold. It is apparent now that many of these babies are predisposed from before the time when they were born. Mr. HILER. What would lead a doctor at a children's health center to imply that there could be a connection if, in your 23 years of extensive work, you have seen no conclusive studies at all done of the subject? Dr. VALDES-DAPENA. I suppose that the experience of encounter- ing a number of sudden and unexplained infant deaths in that set- ting might at least pose the question: Is there a relationship be- tween SID and life in a trailer? If you are asking me why the sug- gestion of a cause-and-effect relationship came up for that physi- cian, it might have been because of that kind of experience which is, of course, anecdotal and not systematic scientific research. But I can only guess. Mr. HILER. Thank you. Dr. Newhouse, you indicated at least three times in your pre- pared testimony that there is absolutely no scientific evidence to support the proposition that UFFI causes cancer in man. Will you elaborate on that? In my view, the testimony of yesterday's witnesses lacked a cer- tain precision while at the same time they raised tentative and open-ended concerns. We have in this country a ban on UFFI as an insulation material. We now have another agency of our govern- ment, HUD, considering standards in manufactured housing based on the Consumer Product Safety Commission's statement that it is a health hazard. Would you respond to, or comment on the issue raised by these policies, actual and proposed. Dr. NEWHOUSE. I understand that you wish me to elaborate spe- cifically on the area of malignancy in relation to UFFI. The only answer, I think, that I can give you about that has to take into account the possible risk of formaldehyde exposure. As an aside, before I get back to the main issue, I should add this. In Canada, I think that people are now starting to accept that PAGENO="0398" 394 the domestic concentrations of formaldehyde, such as those which would result from UFFI, even with bad installations and even with the relatively high levels of over 0.1-we might discuss later why 0.1 has been chosen as. a standard because the evidence for that is not great either. Even if you took 0.1 as the standard, about 10 percent of the homes in the Canadian survey, about 2,000 homes, turned out to have over 0.1. Interestingly, in Quebec, a Dr. Nantel, who is a pro- fessor of toxicology at Laval, showed that there appears to be a great. deal more illness in general than there is in the rest of the country, although as far as I know the insulations were no differ- ent in Quebec. Dr. Nantel seems to have seen a great deal of ill- ness. There has been the mention of something like 60 percent of all of the homes which were insulated with UFFI, which have sick people in them. He talks about such things as malignancy related to this disease. He described children from two homes with UFFI-not the same home but two different homes-who died of some sort of malignan- cy. I believe it was a kind of lymphoma. He wondered whether they could be related inasmuch as the homes had UFFI in them. Let me make it clear that no epidemiological studies have been done, but I believe that Dr. Nantel was concerned. He was also concerned about a lot of other illness. He described abcesses and fungal infections and a lot of rare types of infection. He then mentioned to the Canadian review committee, which was looking into the question last summer, a theory which he has pro- pounded; namely, that the people were suffering from something which he called total immunological collapse. That is translation from the French so I cannot vouch for those exact words, but that was his intent. As far as I am aware and from talking to immunological col- leagues, there is no such condition which has ever been described in medicine. They would give no credence to it. It is his hypothesis, and he has no evidence, of which I am aware, to support it. With respect to the question of malignancy and UFFI, one can only extrapolate from the kinds of thing which Dr. Higginson has mentioned. That is, there are people who are occupationally ex- posed to concentrations of formaldehyde which are up to 100 times greater than you would find in a home, who do not have an excess of cancer of any kind. Not a single case of nasal cancer has been demonstrated. It is hard to imagine, if we are talking about formaldehyde as the poisonous substance, that the much lower concentrations in homes, even if you were imprisoned there 24 hours a day, would be likely to cause a problem which the high concentrations in the oc- cupational setting do not. I think it is quite reasonable to make that contention because formaldehyde is a natural substance in body cells. It is not cumula- tive until you breathe more than 6 parts per million. Under 2 parts per million, the enzyme systems in the cells are capable of inacti- vating the formaldehyde, which is naturally present in any case as a byproduct of metabolism. It is unlikely that, in low concentrations even for long periods, that hazards will arise with respect to malignancy. PAGENO="0399" 395 When you look at Dr. Gibson's rat studies, the ones which were reported by the CuT, you may get a little bit of an insight into why the rats got the nasal cancer and why humans are very, very un- likely to do so. In the rats, if you recall-mention has been made of this already-the carcinoma only occurred in significant numbers at 15 ppm; at 6 ppm there were occasional cases. That is, at 15 ppm, for 6 hours a day, for the whole of the rats' life-rats usually die of natural causes at around 24 months. Espe- cially in the last 6 months of their lives-one can draw an analogy to humans because as you grow older, you tend to have a greater susceptibility to malignancy because your surveillance systems are not as effective. Almost 50 percent of these rats got carcinoma of the nose. I was a speaker, 10 days ago, at a meeting in Toronto called Formaldehyde: The Facts. It was organized by the Southern news- paper chain to look into the whole question. At that meeting, Dr. Gibson spoke. He presented considerable detail about his rat stud- ies. I would recommend to this committee that you ask him to come and present his data. I will try and do the best I can to explain what I understood from his data to you. He analyzed the anatomical structures of the rats at various stages throughout the study and found that at 15 ppm, but not at 6 ppm, severe necrosis, that is, severe damage of the lin- ings of the rats' noses occurred. Such injury leads to a very rapid turnover of nasal cells in the rats, and similar injury is thought by reasonable medical scientists, if it goes on long enough and is severe enough, to predispose to malignant change, in. part because the turnover of cells is so rapid, and mutation is more likely to occur. He made some calculations comparing the rats who developed the cancer with the mice who did so in only 1 percent of the cases, if you recall, which were exposed under almost identical conditions. It seemed strange that these two different kinds of rodent have such different experiences. He found, when he calculated the volume of formaldehyde per minute to which they were exposed, that the rats were exposed to 0.114, whereas, the mice were ex- posed to 0.012. There was a tenfold difference in the exposure. Second, the surface area of exposure of the rats was 13.4 com- pared to 2.9 for the mice, which again is a sixfold or fivefold factor. If you work out the dose per minute per square centimeter, you find that the rat is 0.15, whereas, the mouse is only 0.076. Therefore, the rats received for the 15 ppm, twice the dose. This is important because, at 6 ppm in the rats, very little oc- curred. They did get a few cancers, but it was very unusual. Below 6 ppm, there was not significant malignancy. This may be a kind of threshold. The evidence for mutagenicity of formaldehyde is weak and in- significant. You wonder why cancer only developed at only the 15 ppm rates. He then looked at cell proliferation in the rats, as I mentioned earlier. When you start to injure tissue, there is a tremendous turnover of the cells. Cells die and other cells replace them. I be- lieve he used carbon-14 tracings to evaluate this, but I cannot PAGENO="0400" 396 speak to that because I do not have the study which was only re- ported and is not in press. He did some controls at 0.5 and 2 ppm, and then he studied 6 and 15 ppm. He found that the rate of turnover in the rats was 0.2 for the controls. At 0.5 ppm of formaldehyde, it went up to 0.38, just about a twice as rapid cell turnover. At 2 ppm, there was no difference, that is, he found the cell turnover to be about the same as at 0.5. At 6 ppm, the cell turnover went up to 5.4. That is, it went up to 15 times what it had been at 2 ppm, and at 15 ppm, the cell turnover dropped to 2.8 as a reflection of very serious cell injury. What I am getting at is this. The histology, that is, the micro- scopic and macroscopic assessment of the tissue from the rats, shows massive alterations, surface damage, and severe injury from irritant properties at high levels. The next question to which Dr. Gibson addressed himself was whether this was a reversible change. He withdrew the formalde- hyde exposure. Within 3 months, 50 percent of the rats had no evi- dence of dysplasia, which is an early change in the tissue, and none of the rats had metaplasia, which is another precancerous change. In other words, this is a reversible thing if you remove the injury. The conclusion I draw from this is that massive cell damage does lead to cell proliferation. In rats it certainly leads to a high inci- dence of cancer of the nose. There is no doubt about that. However, if one draws the analogy to man, even in industries where people are exposed, that situation has not occurred. Therefore, it may be like the difference between the rats and the mice. It just means that, while humans may be mice, they are mostly not rats. Mr. HILER. I am happy to hear that, Dr. Newhouse. [Laughter.] I would like to follow up on that. Did Dr. Gibson make the jump from saying that, while formaldehyde may cause cancer in rats at 15 ppm over an extended period of exposure, that it follows that it causes cancer in man? Did Dr. Gibson make that finding? Dr. NEWHOUSE. We have to go back one step, I think. If the claim is that-some toxicologists have made the claim that you cannot extrapolate from the lack of nasal cancer in industrial workers who are only exposed for a certain number of hours per day to high concentrations to the potential for causing cancer in mobile home dwellers or people exposed to UFFI in their walls who are exposed to very low concentrations for long periods and, in the case of infants or old people, may be stuck there 24 hours a day. That claim has been made. Gibson's evidence suggests that, on the contrary, if anyone is going to get cancer from formaldehyde, it will be the people who are exposed for short periods to high concentrations like the rats were. The rats were exposed for 6 hours a day to 15 p.p.m. The dwellers are not exposed to anything like that, and inasmuch as formaldehyde does not accumulate in cells and inasmuch as there is no evidence that the workers have necrosis of their noses, it is unlikely that the homeowners will get cancer, and there is no reason to think that the workers are likely to get cancer, although the final word on that is not in. The five studies which are available at the moment suggest that it is not so. PAGENO="0401" 397 Mr. HILER. What I find very interesting is that we had several witnesses yesterday, and the Consumer Product Safety Commission today, who cited the CuT study as the reason why UFFI was banned. And yet the originator of the study is not willing to make that assumption at all. Dr. NEWHOUSE. On the contrary, Dr. Gibson went out of his way to say that you could not extrapolate these data to man. Inasmuch as mice did not seem to be doing the same thing, and he could figure out why. After he did the turnover studies, he felt-again, I am interpret- ing him to you. I must apologize for that because I do not think it is fair. It would be better were he here so that he could speak for himself. The impression I got from him at the Toronto meeting was that he felt that one could certainly not extrapolate his findings to man. He would not do so. Mr. HILER. Dr. Higginson, we are coming to the end of a 2 long days of hearings on this question. We have heard from a great many people who have experienced serious personal difficulties. Depending upon various view points they may or may not be relat- ed to formaldehyde. Nonetheless, they are serious personal difficul- ties. We have received a great deal of conflicting testimony from the scientific community. The views expressed by this panel today are significantly different from the panel of experts which testified here yesterday. Congress finds itself in the position of having to deal with highly technical issues, while Members lack the expertise, often, to make personally informed judgments. We see our colleagues in Canada considering a $110 million program to compensate for problems about which you all differ. Now we have a bill introduced in our Congress to establish a similar program. How can we resolve these conflicts and questions at the public interest level? Dr. HIGGINs0N. Sir, I think a lot of people have been trying to answer that question. When you have a parascientific regulative decision which includes socioeconomic as well as scientific issues. I think the issues, should be separated. - I have had experience in the last several years in dealing with scientific issues in the IARC. For over 15 years, we found that we could hammer out a good consensus of opinion on the scientific issues. How that is dealt with by national bodies in the totality of all issues is another matter altogether. As we are organized in this country, we do not have available any external methodology beyond the academy and certain other bodies with this potential. One of the things I am trying to do is to see whether I can create within the group of universities with which I am associated a kind of panel to deal with the scientific aspects, objectively and neutrally, so that when at least the input reaches this floor, it represents a kind of consensus. The problem arises when you start to mix apples and oranges, nonscientific and scientific issues, one to justify the other. Then you do not really know which is correct. I think we could do better on the scientific issues, sir. Mr. HILER. Would either you, Dr. Newhouse, or you, Dr. Dapena, like to follow-up on Dr. Higginson's comment? 97-153 O-82---26 PAGENO="0402" 398 Dr. VALDES-DAPENA. I would like to make one comment: This committee is charged with the responsibility of coming to some kind of conclusion about formaldehyde and its use in the building industry. My one concern is that the final judgment be based upon sound scientific data. Nothing less than that is worthy of this group's consideration. Mr. HILER. It would be your opinion that there are not sound sci- entific data to date. Dr. VALDES-DAPENA. That is my opinion. Mr. HILER. Dr. Newhouse? Dr. NEWHOUSE. I agree entirely with Dr. Dapena. I do not think that decisions like this can be based on other than science, or we are all back to the Salem witch trials and the miasmas of the night air. We can do better than that in a modern society which can put men on the Moon and satellites around Venus. I do not think that a committee like this should be satisfied with less than the best expert opinion it can get. I want to emphasize what I said earlier. That is, when you have a new chemical being presented to the marketplace which may not be much of an improvement over what went before anyhow and which has not had proper studies done to assure its safety in a number of ways, as a sensitizer or as a carcinogen, then I think it is reasonable to hold the chemical off the market, as we now hold drugs off the market until the cost-benefit ratio has been estab- lished. With something which has been around for a long time, like formaldehyde, gasoline, propane, or something, I do not think you can just go banning things based on a lot of subjective complaints. That is absolutely ridiculous. I think one has to have scientific evi- dence that it is a hazard. If it is, we may have to turn the whole country upside down to purge formaldehyde from our environment. However, I do not think that you start doing the purging in any way-you do not do any banning-until you have proven it for something which has been around for 100 years. I do think that you need the best expert advice you can get. As an aside, in Canada there was a scientific committee consti- tuted by the government to advise the government. I know some of the members of the committee. I think that they acted as academ- ics, rather than as people living in the real world. That is a real danger among scientists. That is, if you are asked to prove the null hypothesis, which means that you are asked to prove that something will never happen, that is absolutely impossible scientifically. As a result, some of my colleagues will hedge their bets by saying that they have not proven the null hypothesis, and inasmuch as the null hy- pothesis is not provable, they will equivocate. That is what happened, I think, on the committee. They equivo- cated to the Minister of Health in Canada. That, plus the effect of media distortion of the symptoms, led to a snowballing political and social problem which could only end up on banning because the Minister of Health was put in the position of having to protect the populace from an unknown poisonous gas. Mr. HILER. I deeply appreciate your contribution to these hear- ings. PAGENO="0403" 399 Of course, one of our major concerns is about the relationship of formaldehyde to the manufactured housing industry. It is a very important industry and a very important housing option for many people in Canada and in the United States. In the State of Indiana, from where I come, manufactured hous- ing and the recreational vehicle industry are the third largest em- ployers in the State. Last year, over 250,000 people were able to find affordable housing through manufactured homes, good homes which are constructed well. Certainly, any time that a question is raised that a compOnent which may be in those homes may be carcinogenic, or that it can in any way relate to the health and safety of the home's occupants, it is a cause for great concern. I am happy to see that the three of you today have thrown a wrench into some of the testimony which was presented here yes- terday. I believe you have demonstrated-certainly to me-that the amount of scientific evidence is greatly lacking as to the fact that there may be a relationship between UFFI, formaldehyde, and a cancer risk to man. I thank you all for coming. Thank you very much, Mr. Chairman. Mr. ROSENTHAL. Thank you all very, very much. Mr. Howlett and Mr. Ehrle, we will break for lunch now in view of the fact that it is now 1:30. We will reconvene, if you have no objection or major problem with it, at 3 o'clock. The subcommittee stands in recess. [Recess taken.] Mr. ROSENTHAL. I am sorry to be late. We had four or five votes on the floor of the House of Representatives. We had to stay there. Mr. Howlett and Mr. Ehrle, we are delighted that both of you could be with us. Again, I apologize for the delay. Mr. HOWLETT. It is a pleasure to be here, Mr. Chairman. Mr. ROSENTHAL. Why do you not proceed. STATEMENT OF CLIFFORD T. HOWLETT, JR., VICE CHAIRMAN, FORMALDEHYDE INSTITUTE Mr. HOWLETT. Thank you. I have submitted a statement for the record. It includes a substantial number of enclosures which are referenced in a table at the back of my testimony. I hope that the enclosures will be included in the record along with my testimony. I am Kip Howlett, Jr., vice chairman of the Formaldehyde Insti- tute and chairman of its government affairs committee. On behalf of the Formaldehyde Institute, which is an association of over 70 companies and associations which produce or use formaldehyde, I want to thank you for the opportunity to make this statement today. The recent national commitment to energy conservation has re- sulted in a growing interest about the impact of reduced ventila- tion in indoor air quality. Less than 4 years ago, the Federal Government began to address the question. At that time, the wood products and formaldehyde- producing industries launched a major research program address- ing technological options to reduce formaldehyde emissions and PAGENO="0404" 400 conducted health research to determine what may be needed to ensure the continued protection of public health. The results are as follows. New technologies have been developed and old technologies im- proved. A new generation of low-formaldehyde wood products is on the market, which represents a 65- to 95-percent reduction in form- aldehyde release. Self-imposed industry standards are now in place. Moreover, we support their inclusion in the HUD mobile home con- struction regulations. We have met with CPSC's engineering staff to review the research efforts. The use of these products in home construction will result in levels of formaldehyde exposure, which are predicted in tests simu- lating home conditions, to be below the levels established by Min- nesota, namely 0.5 ppm, and Wisconsin, namely, 0.4 ppm, for the permitted exposure limitation in all homes or mobile homes, re- spectively. The judicial decision in Massachusetts overturning that State's ban of UFFI and classification of formaldehyde without regard to level as a hazardous substance, the recent National Academy of Science Report on Formaldehyde, the National Institute of Occupa- tional Safety and Health, and a Formaldehyde Institute medical committee report have made the following points: The elimination of all exposure to formaldehyde is not necessary to protect the general population from acute effects~ The odor-irritation threshold for formaldehyde in the general population is about 1 part per million. A level of 0.5 ppm will not result in symptoms or sensory irrita- tion for nearly all but the most sensitive individuals, whose exact proportion of the population is not known but is estimated to be extremely small. Concern about chronic effects has increased after the CuT chron- ic inhalation study found in rats only a statistically significant rate of nasal cancer at the highest exposure level of 15 ppm. No nasal cancer was seen at all in mice at 6 or 2 ppm or in rats at 2 ppm. The animals were exposed to levels which no human would toler- ate. There are clear and distinct no-observable-effect levels in the tests. Other tests, many at CuT, are building the scientific evidence on the mechanism of a threshold for formaldehyde's carcinogenic effect. NIOSH and the American Cancer Society have stated that there is no evidence that formaldehyde is a human carcinogen. Industrial use of formaldehyde has occurred since the turn of the century. A growing list of epidemiological studies and reports from the United States, Great Britain, Finland, New Zealand, Denmark, and Ger- many have been reported. There are 10 enclosed with this testimo- ny. The Danish report provides an excellent summary for all the studies: Long-term formaldehyde exposure in man is unlikely to carry an important risk for lung cancer * * * the examination of a possible carcinogenic risk to man from formaldehyde shall be concentrated on more proximal parts of the respiratory tract, i.e., the nasal cavities, a target for which there is so far no evidence of an increased risk in humans. The reference is taken from Lancet, April 17, 1982, page 913. PAGENO="0405" 401 The biodynamics study sponsored by the Institute tested almost 400 animals of three species: the rat, the monkey, and the hamster. No damage due to the formaldehyde exposure was detected in any of the animals exposed nearly continuously for 6 months to 0.2 ppm and 1.0 ppm of formaldehyde, which are levels which consum- ers might encounter. At the 3.0 ppm exposure level, there was in- flammation of the noses of the rat and monkey, detected by micro- scopic examination, but the inflammation was reversible when the exposure ceased. The vast majority of the recently reported studies were industry- sponsored. Over 50 more studies are planned or underway. Most of them are industry-sponsored too. Having completed this brief overview, I would like to return to each of the points and provide a little more detailed information. Formaldehyde, as you have heard from other speakers today, is ubiquitous. It represents something of a paradox. We could hardly live without it. Our bodies produce it as a necessary metabolite to sustain the life process itself, and our chemical plants also produce it. Yet, many people are uncomfortable just thinking about formal- dehyde. We need to understand both the contributions and limitations, the good and the bad, of a chemical which has justifiably been called a building block of our society. Formaldehyde was first manufactured in 1889 and has become an indispensable ingredient in the production of thousands of in- dustrial and consumer products. A partial list is enclosed with this testimony. Today, about 1.4 million Americans are involved in making form- aldehyde or formaldehyde-containing products. Those workers, em- ployed in about 45,000 U.S. facilities across the country, earn about $18 billion per year. In 17 major industries, formaldehyde is essen- tial to plant operations. In another 70 industries, it is an important basic raw material. In fact, formaldehyde manufacture and use ac- counts for about 8 percent of America's $3 trillion gross national product. More formaldehyde is produced as a byproduct of natural or man-made processes than is manufactured by design. Formalde- hyde is present in tobacco smoke. Incomplete combustion of hydro- carbons in wood produces formaldehyde. Automobile emissions alone release over 600 million pounds per year. Formaldehyde is present in urban air with levels occasionally reaching 0.15 ppm. Formaldehyde is even present in the air in Antarctica at 0.01 ppm. There is a table enclosed of references on ambient levels which have been reported in the literature. Technological research on indoor air quality has been a major part of the institute's program. Energy conservation efforts in the late 1970's have reduced ventilation rates in residences and com- mercial buildings, and a corresponding concern has grown about potential increases in levels of residential indoor air contaminants. Common indoor pollutants which can be present in some prod- ucts used in the home and lifestyle habits such as cooking and smoking include carbon dioxide, carbon monoxide, nitrogen oxides, solvents, particulates, fungi, spores, radon, and other compounds. PAGENO="0406" 402 Contemporaneous with this general concern, HUD began to ad- dress the impact of the new federally mandated mobile home con- struction standards on indoor air quality. The wood products industry with the assistance of the Formalde- hyde Institute commenced an ambitious research program. At that time, there were over 30 test methods available to meas- ure formaldehyde release from products. Under the leadership of the institute's technical committee, a dynamic environmental chamber test method was developed and perfected, which tests building products in an environment which simulates use in home construction. A recent study by HUD has verified that the test method pro- vides excellent correlations between values observed in the test chamber and values measured in actual home construction. Addi- tional work is ongoing to perfect a quicker and less costly static test method which will provide the same degree of predictability. Several methods show great promise. U.S. technology has improved. Formaldehyde emissions from building products have been reduced from 65 to 95 percent. Ambi- ent levels in conventional houses are below 0.1 ppm, which is the lower limit of detectability with the revised NIOSH test method. American technology is comparable to the level of European technology. Tests of German particle board in a dynamic environ- mental chamber under European specifications-a loading rate of 1.4 m2/m3, 23° C, 45 percent RH, and one air change per hour- which have a higher loading rate and more ventilation than does the U.S. chamber setting, are predicted under the German volun- tary standard and coding system to meet an indoor formaldehyde level under those conditions of 0.1 ppm. Recent reports, one in a European journal which is enclosed with this testimony, on these materials showed a test result of 0.3 ppm. German particle board panels have also been tested in a large environmental chamber under U.S. conditions, which have been validated through HUD's research. These conditions involve a lesser loading rate but higher temperature and a lower ventilation rate-0.46 m2/m3 loading rate, 25°C, 50 percent RH, and 0.5 ACH. Ambient formaldehyde levels in the chamber measured 0.26 ppm. When tested 5 months later, the ambient level measured 0.24 ppm. While Germany has a guideline requiring no more than 0.1 ppm formaldehyde in the ambient air of living units, no actual testing of living units has been reported. There is an assumption that, if all building products used in home construction meet the German standard, then the ambient air specification will be met, but no one appears to know how well these relate to the actual use. Fortunately, in the United States, through intensive research ef- forts of industry and HUD, the relationship between product per- formance standards and resulting indoor ambient levels has been addressed. Several suppliers of products used in home construction have de- veloped product performance standards which are related to a 0.5 ppm indoor concentration under specified conditions designed to replicate the home environment. The Formaldehyde Institute sup- ports efforts to incorporate such product performance standards PAGENO="0407" 403 and to require that products subject to such performance standards be utilized. The National Particleboard Association and the Hardwood Ply- wood Manufacturer's Association have put into place industrywide standards on formaldehyde release from these products. In addition to formaldehyde release rates from products, the amount or loading of the products in home construction, ventila- tion can also be another key factor in protecting indoor air quality. Several Government agencies, such as the Environmental Protec- tion Agency, have recommended that at least one air change per hour is necessary to protect the indoor environment. Some construction practices may result in extremely low rates of natural air infiltration. If air change rates are below one air change per hour-ACH-then use of air filtration devices, heat ex- changers, or mechanical means to increase fresh air makeup should be considered, after careful review of energy costs, and re- quired where necessary. How realistic is the 0.5 ppm standard? Health effects have been studied. First, I would like to address chronic effects. The animal exposures in the CuT chronic inhalation tests are not comparable to those experienced by the human population. A rat can be forced to live in a 15 parts per million atmosphere which is totally intolerable for humans. There are clear and distinct no-observable-effect levels in these tests. There are distinct differences in the way different animal species react to formaldehyde exposure. Even at the same ambient concen- tration, depending on the physiology and biological mechanisms, different animal species will have different effective doses. The mechanism of how carcinogenic effects occur is critical. The high level of exposure which causes the nasal cells to be destroyed in rats exposed to 15 ppm initiates massive and rapid cell repair- cell proliferation-and cancer is, therefore, a secondary effect which occurs only if extremely toxic doses are reached. The concentration of formaldehyde-a high dose-is the most im- portant factor in determining cancer risk based on the animal data, more important than the accumulation of low doses over time. The CuT final report shows that formaldehyde at a high dose of 15 ppm was carcinogenic in the rat only. In mice, at the highest level of 15 ppm and in rats at the intermediate level of 6 ppm, the incidences of tumors were not found to be statistically significant. The finding of carcinogenicity in one species at the highest level was later confirmed by NYU [New York University]. The Formaldehyde Institute's biodynamics study tested 400 ani- mals of three species-rat, monkey, and hamster-at 3 ppm, 1 ppm, and 0.2 ppm. No damage due to exposure was detected in any of the animals exposed nearly continuously at the levels of 0.2 ppm and 1.0 ppm, which are levels which consumers might encounter. There are lifetime studies in other animal species testing for car- cinogenic responses to formaldehyde, which have produced nega- tive results. Human epidemiology is probably the most persuasive evidence. Epidemiologic studies reported to date-and the list is growing- PAGENO="0408" 404 have reported no excesses of either nasal or oropharyngeal or other cancer types due to chronic formaldehyde exposure. Despite the negative studies we have, further epidemiologic stud- ies should be done to better establish safe levels of chronic formal- dehyde exposure. Further studies are indeed currently underway. The definitive cancer mortality study is a cohort study involving 17,000 formaldehyde workers by the National Cancer Institute and the Formaldehyde Institute, which is well underway. Another epidemiologic study in the United Kingdom will review 10,000 to 12,000 workers who have experienced longterm-15 years or more-exposure to formaldehyde. The FNCI study will be final in 1984, and the U.K. study will be completed next year. The epidemiologic studies, while individually considered, may in- volve small study populations. They should be viewed as a whole. No evidence of formaldehyde as a human carcinogen has been re- ported in the scientific literature. Moreover, the issue of carcino- genicity must be addressed by balancing all of the animal test data, both negativi and positive, with the human experience. When this is done, even the CPSC risk assessment estimated that the chronic risk at levels of exposure typically encountered in the home environment was essentially zero. Formaldehyde is a well-known chemical irritant, exhibiting its main toxic effects on the upper respiratory tract, eyes, and skin. The upper respiratory tract has been identified as the target organ for acute and chronic inhalation effects in recent laboratory experi- ments. Attempts have been made to establish irritant thresholds for for- maldehyde exposures. Evidence from a controlled chamber study with volunteer subjects indicates a threshold for sensory irritation at levels of formaldehyde from 0.8 to 1.2 ppm. NIOSH, in an exten- sive literature review, concluded that the irritant threshold for the normal human population is 1 ppm. A continuous inhalation study with several animal species indicates that there is no cellular damage at this or lower levels of formaldehyde exposure. At concentrations from 0.4 to 0.7 ppm, formaldehyde produces some sensory irritation in some subjects, but the response is not as strong as that seen at higher levels. Subjective responses of slight discomfort were reported at levels below 0.5 ppm, but no dose-re- sponse relationship was established. Regarding pulmonary allergic responses, there is no scientific evidence that ambient exposure to formaldehyde produces pulmon- ary sensitization reactions. It should not be overlooked that other airborne substances com- monly found in the home are also capable of producing variable, nonspecific complaints and irritant symptoms similar to those re- ported for formaldehyde. The Center for Disease Control recently held a conference which focused on indoor air quality; 22 case his- tories were studied. Nausea and vomiting were reported for each case. Investigations were undertaken in each case to determine the causative agent. Formaldehyde was not found in these environ- ments at measurable levels. Substances such as solvents, Fiberglas, rug shampoo, fungal spores, and dust were identified as the prob- able etiologic agents. PAGENO="0409" 405 In summary, indoor air pollution is an important issue which needs to be addressed. Common indoor pollutants which can be present in products used in the home, and lifestyle factors such as cooking and smoking, include carbon dioxide, carbon monoxide, ni- trogen oxide, solvents, particulates, fungal spores, radon, and other compounds. Formaldehyde is one of the substances which is pres- ent in background air, generated by lifestyle factors, and used in a wide variety of products. There have been significant breakthroughs in recent years in re- ducing formaldehyde emissions from products such as wood panel- ing, furniture, particle board, and other household products. The reduction in formaldehyde release has occurred because of the in- dustry's commitment to a program which was started about 3 years ago. Industry's research efforts and technological advances and the implementation of industrywide standards can be contrasted with the Federal research effort on indoor air quality, which the Con- gressional Office of Technology Assessment characterized as piece- meal. OTA-Office of Technology Assessment-concluded: "It is crucial that the-energy-conservation effort be closely coupled with the program to expand our understanding of indoor air quality as well as measures to protect the environment * * * the Federal research effort on indoor air quality has been limited to a few, small piece- meal contracts." While there is some Federal effort to determine what effect changes in ventilation rates have on levels of indoor air quality, there is at present no federally funded program examining the health effects which may result from continuous low-level exposure to all the pollutants which are commonly found indoors. To this end, the Formaldehyde Institute and its member compa- nies are proud of the important and groundbreaking research which we are doing relative to formaldehyde's presence in the indoor air. Our goal has been to be part of the solution, not part of the defi- nition of the problem. I would be pleased to answer any questions you may have. Mr. ROSENTHAL. Thank you very much. Mr. Ehrle will be our next witness. Without objection, the attachments to Mr. Howlett's testimony will be inserted in the record at this point. [Attachments to Mr. Howlett's prepared statement follow:] PAGENO="0410" * Ut toar sns~lataon wax and butcher wet strength paper perma press cotton * plastic * plywood * muldina compounds * fiberglass and mineral wool * formica * pressed wood furniture * brake drums * plastic parts for vehicles * plunbing fixtures * hardware * lawn and garden equipment * spurting goods * counter and table tops * melamine tableware * resins and oil based paints * explosives a vinyl resins * electrical insulation parts * nitrogen fertilizers * phenolic terxcasetting resins * tire rubbers * insecticides * pharmaceuticals * textile treating agents * detergents * water softening chemicals * urethane coatings and resins * antihistimines * aerosol insecticide * dyes for textile industry * embalming agents * anti-perspirant formations * oral hexasnethlenetetramine medication * drinking milk * dental filling * `dust sterilizing solutions * hair waving preparations * deodorants -* * nail hardener * glues * acrylic * wool * nylon fibez's * photo chemical smog * cigarette smoke mascara and cther cusretics barber and beauty shup disinfectants * air fresheners * dry cleaners for disinfectant * fiber board * air and furnace filters * furniture adhesives * binding on paper bag seams * plaster of paris castings * orthopedic casts and bandages * binders for sand foundry cores * coated papers used for cartons and labels * coatings for appliances * primer coats for automobiles paint and wood finishes * housings for electric shavers and mixers * electronic equipment * soap dispensers * stove and refrigerator hardware * toilet seats * knob and buttons utensil handles * shampoo * nail polish * mildew prevention * synthetic lubricants * textile water-proofing * flour preservative * wheat grains and agricultural seeds * facial tissues and napkins * hospital bed sheets * examining table paper rolls * dental bibs * diaper liners * some filter papers * rayon * drapery and upholstery fabrics * carpet and upholstery latex backing * non-woven binders and flock adhesives * softeners and lubricants * - flame retardants * - anti-slip agents * antistatic agents bactericides and napping agents * sanforized cottons * leather tanning * preservatives * vaccines * automotive exhaust * water filters 406 insulation binders PAGENO="0411" 407 OUTDOOR CONCENTRATION OF FORMALDEHYDE (ppm) STUDY - RANGE MEAN (X) Frank, et al University of Iowa 0.00041-0.0056 0.002 Renzetti/Bryan, 1960 J. Air Pollut. Control Association Los Angeles Smog 0.0-0.13 0.065 Altshuller, et al, 1963 3. Air Pollut. Control Association Los Angeles Atmosphere 0.005-0.150 0.075 Scott Research Labs, In 1968 Nat. Air Pollut. Contro Administration Huntington Park, Calif. . 0.004-0.136 0.066 Scott Research Labs,Inc 1968 Nat. Air Pollut. Contro Administration El Monte, California 0.0-0.09 0.045 Breeding, ct,al , 1973 Antartica <0.00005-0.01 0.0095 97-4~,3 1172 PAGENO="0412" 408 DOCUMENTS IN SUPPORT OF TESTIMONY by C.T. Howlett, Jr. Vice Chairman, Formaldehyde Institute Before the U.S. House of Representatives Government Operations Committee Commerce, Consumer and Monetary Affairs Subcommittee May 19, 1982 General Statements: American Cancer Society Statement National Institute of Occupational Safety and Health Mortality Study Protocol National Academy of Sciences Report on Formaldehyde, Chapter 7, Health Effects Judicial and Administrative Decisions: Massachusetts State Court Decision Overturning UFFI Ban Wisconsin Department of Industry, Labor and Human Resources Regulation on Ambient Formaldehyde Minnesota State Department of Public Health Rule on Formaldehyde and Decisions of Adjudicatory Hearing Examiner and Chief Hearing Examiner Research Projects: Summary of Ongoing Research Recommended by National Academy of Sciences and Federal Toxicology Panel on Formaldehyde Epidemiology Studies: "Overview of Reported Epidemiology Studies", Dr. Walter C. Barnes Chemical Workers Study, Otto Wong Chemical Workers Study, Gary Marsh New York Embalmers Study, Walrath and Fraumeni Pathologists, Mantonski Pathologists and Medical Technicians Study, Harrington and Shannon PAGENO="0413" 409 International Studies: Denmark, Dr. Jenson East German Report New Zealand Study Finland Study England and Wales Study Cancer Research: CuT Summary, Dr. James Gibson CuT Mutagenic/Mechanism Studies Litton Bionetics In Vitro/In Vivo Abstract Haskell Laboratories Initiator/Promoter Abstract Risk Assessment: Correspondence of Dr. Sidney Firstman regarding CPSC rulemaking, December 1981 and February 1982 Society of Toxicology Presentation, Dr. lb Andersen Dr. John Higginson letter to CPSC, Feburary 12, 1982 Professor Robert Sielken letter to CPSC, February 15, 1982 Technical: West German Report on Particleboard COPIES OF THESE DOCUMENTS AVAILABLE UPON REQUEST PAGENO="0414" 410 STATEMENT OF WILLIAM L. EHRLE, NATIONAL MANUFACTURED HOUSING FEDERATION, INC. Mr. EHRLE. Mr. Chairman, I am sure you can read perfectly well, so I will not bore you by reading my complete statement. You are perfectly capable of doing that. In the interest of time, let me sum- marize it, if I may. First, I want to say this in response to something which the chairman said or asked earlier today and perhaps yesterday. This is my position, basically, although it is not stated here. Incorporated in the essence of this statement is the fact that the Federal Government is involved, and there is a Federal presence in connection with indoor air quality and in connection with formal- dehyde found in the ambient air of residential structures. The Fed- eral Government does have a responsibility. Let me give you an example related to manufactured housing. The HUD Manufactured Housing Standards code even sets the moisture content for* the studs-the lumber and 2 by 4 or 2 by 6- which go into the interior and exterior walls of the manufactured homes. If the Federal Government has undertaken and did under- take, as far back as 1976, regulation to that degree, namely, of the moisture content, then I simply submit to you that the Federal Government also has an obligation to the purchasers, the occu- pants, and the inhabitants of manufactured houses, who purchase manufactured houses, and has an obligation to the manufactured housing industry to tell us if the formaldehyde content at some level should be maintained in the interest of public health and safety. There is a Federal presence. The Federal Government does have a responsibility, a very definitive one, in my opinion. I am representing today the National Manufactured Housing Federation. I shall point out some statistical information and point out on page 4, Mr. Chairman, the public interests involved in affordable housing. There is no point in reciting all of that. We all know that there is a real crisis in America today in connection with available, affordable housing. A great many of our blue collar, lower income families simply cannot afford site-built homes today. On page 5 I refer to the HUD code. As I mentioned, it even sets the moisture content for much of the lumber which goes into the construction of these homes. The HUD code requires a very tight thermal envelope for manufactured homes. An air-exchange ratio-as Mr. Abrams responded to your question this morning-is not specifically set out, but what does occur is as a result of the energy efficiency requirements and the heat loss and heat gain cal- culations which go into the determination of that performance. It requires an approximate 0.3 air exchange rate per hour in a manu- factured home. Let us contrast that with the three major construction codes: Southern Standard Building Code, Uniform Building Code, and the BOCA-Building Officials Code Administration-Code. If you built to the minimum performance levels of those codes, you would have in a site-built structure an air exchange rate of from three to five times per hour. That is from 10 to 17 times greater than the air PAGENO="0415" 411 exchange rate which is allowed by HUD today in manufactured homes. Obviously, air exchange rates are a substantially important factor when considering any substance in the indoor environment. If the substance-formaldehyde in this instance-is less in the out- side air, and the air exchange rates from outside to inside are greater, you will have less formaldehyde in the presence of the home at any particular time in the living environment situation. We have, once again, competing aspects of the public interest. We have the public interest involved in energy conservation and very low utility bills. Then we have the public interest involved in maintaining the excellence of air quality inside. Let me stress this again. The subject which I think the Federal Government will eventually have to address, although formalde- hyde is perhaps the public issue at the moment-is that of indoor air quality because, as I point out on page 7, there are 40 different major substances which are typically found in the indoor air. That is not a complete, conclusive list. Many, many things are found in the indoor air of homes, normally at very low levels. That includes formaldehyde. However, once you tighten the thermal envelope of the structure so that the air exchange rates do not allow transfer of air, you have trapped the normal toxins which are present in any environ- ment, even in this hearing room today. If the air exchange rates are not there, this room will not be livable after some period of time depending upon what the environment is inside the room. The substances can act by themselves, or they can act in concert. As I point out in the statement, without a doubt some of the var- ious substances by themselves might be at what one might call a very low or safe level, but they can act together synergistically to cause the kind of symptoms which have been alleged to be caused by formaldehyde. The truth is that it is really not possible, based on the scientific evidence today, to say that formaldehyde did it. What I would like to do is to show you that there is really no conflict between the testimony of some of the witnesses yesterday and the witnesses today. I think the consumers and homeowners who were here sincerely believe that their physical problems were occasioned by formaldehyde. I am certain of that, as I am sure the chairman is. Yet We found Dr. Newhouse testifying today that there is no scientific evidence really on which to base claims that formaldehyde did that. I submit, Mr. Chairman, that those are not necessarily polarized statements or positions. The situation could well be that, as a result of the application of the UFFI and the thermal energy re- quirements, the tight thermal envelope in manufactured homes, we are simply trapping inside these structures many substances which act synergistically to produce the symptoms. I think that is not only possible; I think, under the circumstances based on the testi- mony you have heard, that it is highly likely. Mr. ROSENTHAL. Let me ask a question. Without objection, your full statement will be inserted in the record at this point. [Mr. Ehrle's prepared statement follows:] PAGENO="0416" 412 TESTIMONY OF WILLIAM L. EHRLE May 19, 1982 BEFORE THE COMMERCE, CONSUMER, AND MONETARY AFFAIRS SUBCOMMITTEE HON. BENJAMIN ROSENTHAL, CHAIRMAN OF THE COMMITTEE ON GOVERNMENT OPERATIONS UNITED STATES HOUSE OF REPRESENTATIVES Chairman Rosenthal and Members of the Subcommittee: My name is Will Ehrle; I reside in Austin, Texas; and I appear before the Subcommittee today to present testimony on behalf of the National Manufactured Housing Federation. The National Manufactured Housing Federation (NMHF) is a non- profit trade association whose membership consists, as of this date, of 31 state and regional manufactured housing trade associa- tions. These state and regional associations are comprised of an aggregate of approximately 30,000 niember business firms which are engaged in the retail sale of manufactured homes and in the devel- opment and operation of manufactured housing communities across the country. In addition, a number of the state associations represent PAGENO="0417" 413 members engaged in the manufacturing of homes. Thus, the National Manufactured Housing Federation is the only organization at the national level which speaks for a large and broad cross-section of the manufactured housing industry. By way of additional background, while I speak today as a re~ presentative of NMHF, I am President and General Counsel of the Texas Manufactured Housing Association. In this capacity I repre- sent all segments of the manufactured housing industry: manufac- turers, retailers, park and community owners and operators, mort- gage bankers and financial institutions engaged in financing the purchase of manufactured homes, insurors of homes and suppliers of various goods and services to the manufactured housing industry. Texas is the leading state in both the production and sale of manufactured housing and this site-delivered housing is a vital part of the housing market in my hone state -- as it is across the United States. It has become virtually the only source of new single family homes which cost less than $40,000.00, and manufac- tured housing provided more than one out of every three (36%) new single family homes built in the United States in 1981. We project that in the next five to seven years factory-built, site-delivered hones (both mobile/manufactured and modular hones) will account for over fifty percent (50%) of all new single family residences which are annually constructed in this country. Thus, Mr. Chairman and Members of the Subcommittee, in your deliberations and consideration of the issues and questions which 97-153 0-82-27 PAGENO="0418" 414 develop as a result of this hearing -- please remember that any action which you nay take regarding manufactured housing will affect the availability of affordable housing for millions of American families in the future. The public interest in the avail- ability of affordable housing should be a predominant factor in your consideration. A lack of such availability is beginning to reach the crisis stage in virtually all sections of this nation. The health safety and welfare of your constituent~i~ (as it should be) your major concern, and the availability~or lack there- of) of well constructed, energy efficient housing at an affordable price is impacting the health, safety and welfare of a tremendous number of your constituents. This aspect of the public interest must be ever present as you consider the need, if any, for legisla- tion relating to indoor air quality in residential structures. For example, blue collar working families and minority families that do not have, and cannot afford, adequate shelter are today far more interested in, and concerned about, the availability of affordable housing than in amy other issue relating to housing. Thus, any regulation of residential indoor air quality must be based on hard, concrete evidence (not conjecture or speculation) because such reg- ulation could substantially affect the availability of affordable housing. The primary focus of this hearing has been on formaldehyde found in the indoor ambient air of residential dwellings. I would hope that the Subcommittee would expand its inquiries into indoor PAGENO="0419" 415 air pollution generally because there are many other chemicals and substances which, at certain levels, can cause all of the symptoms which have been ascribed by some witnesses to formaldehyde with the inference that formaldehyde alone, or exclusively, was the cause of such symptoms. This is simply not necessarily true. Indoor air quality in both residential and work-place environ- ments is becoming the subject of increasing concern to many groups, government agencies and the public. A primary factor is, of course, our increased emphasis on energy conservation in these dwellings and structures. Since June 15, 1976, the U. S. Department of Housing and Urban Development (HUD) has regulated the construction of mobile/manufac- tured homes for the protection of the public health, safety and welfare. The HUD-code setting standards and requirements for the construction of manufactured housing is rather stringent and is certainly comparable to other recognized building codes. In some respects the minimum performance standards and requirements for mobile/manufactured homes are stronger, or more stringent or re- strictive, than. the recognized prescriptive codes applicable to the construction of site-built homes. An example relevant to this hearing is in the air-exchange rates, which result from insulation and energy standards. The HUD-code mandates a rather tight "thermal envelope" which results in an air-exchange rate of approx- imately 0.3 per hour. This can be related to comparable energy standards for site-built dwellings which. result in air-exchange rates from 3.0 to 5.0 per hour. PAGENO="0420" 416 Thus, because of the tight, thermal envelope røquired for mobile/manufactured homes, the turn-over of the indoor air, or the rate at which the air inside the home is completely changed, is from ten (10) to seventeen (17) times greater in site-built struc- tures constructed to minimum code requirements as opposed to HUD- code constructed manufactured homes. The air-exchange rates in a home are obviously a substantial factor which affects the quality of the air inside the home. Air- exchange rates are also a major factor in energy conservation; thus, once again we see competing aspects of the public interest, ie., indoor air pollution vs. energy conservation. These competing aspects of the public interest must be balanced -- but, as always, with due consideration to the fundamental interest of the public in the availability of affordable housing. Quite frankly, this is not a simple, easy task; however, it must be done, and preferably by the federal government through composite, coordinated, and reason- able regulation. Since the federal government is already heavily involved in the matter of energy conservation, the myriad of ques- tions and concerns about indoor air quality must be addressed at this level. But, once again, let me stress and emphasize the sub- ject of `~indoor air quality" as opposed to uformaldehydel~ alone. Formaldehyde has been the subject of complaints regarding ir- ritation of the eyes and respiratory tract, nausea, headache, tiredness or fatigue, dizziness and thirst (and virtually every PAGENO="0421" 417 other symptom imaginable). However, many, many other chemicals and particulates cause one or more of the same symptoms. A partial list of these is as follows: Benzopyrene, carbon monoxide and carbon dioxide, nitrogen dioxide, naphthalene, paradichlorobenzene, carbon tetrachloride, chlorine, lye, aminonium hydroxide, hydrogen cyanide, potassium hy- droxide, nitrous oxide, sodium lauryl sulfate, aluminum chloride, vinyl acetate polymer, trichloroethylene, acetone, hydrocarbons, methylene chloride and phenols, toluene, xylene, hypochlorites, butanol, hexane, methlheptane, alpha-pinene, dichloroethane, hexanol, N-decane, and alkane or nonane. In addition, many millions of Americans have allergic reac- tions to various things, and most of the same symptoms (as claimed to be caused by formaldehyde) can be caused by various allergens which become trapped in the indoor environment -- particularly fungi (such as alternaria, riboflous, penicillium, armadendron, and aspergillus) and house dust and house-dust mites. According to experts in the field of allergy and of industrial and environmental hygiene, these various chemicals and other indoor pollutants may produce the same symptoms as claimed for formalde- hyde. These symptoms can be produced by these substances acting singly or in concert. In fact, each substance could be at a level which is l~safeR in the sense that it would cause no symptoms, but several of these substances (even at such "safe" levels) can act as an orchestra in concert to produce the same symptoms. PAGENO="0422" 418 As the reference material and the source for much of my testi- mony thus far, Mr. Chairman, I have filed with the staff five copies of the transcript of sworn testimony before the Texas De- partment of Labor and Standards at a public hearing held on August 6, 1981 relating to a proposed notice or "warning" to consumers concerning formaldehyde in the indoor air of manufactured homes. I, of course, desire to incorporate such by reference in my testi- mony. The National Academy of Sciences, established by congressional charter in 1863, issued a report released in late May or early June of 1981 entitled "Formaldehyde and Other Aldehydes". This report was approved by the Governing Board of the National Research Council whose members are drawn from the councils of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The National Academy of Engineering and the Institute of Medicine were' established in 1964 and 1970, respec- tively, under the charter of the National Academy of Sciences. This report approved by these prestigious groups is a very compre- hensive treatise as to the effect of formaldehyde on human health. * This NAS report produces far more questions than answers about formaldehyde. Let me take the liberty of extracting several quota- tions: PAGENO="0423" 419 "There are some serious deficiencies Ifl our present knowledge of indoor aldehyde sources and concentrations. In particular, studies on the following issues are required to allow a careful assessment of the indoor aldehyde problem: Studies of building materials, particle board, plywood, urea-for-' maldehyde foam insulation, et cetera, from the point of view of their aldehyde emission rates and intervening factors, such as ventilation rate, temperature and humidity; studies to measure the emission of other indoor sources of formaldehyde, such as gas-fired appliances, tobacco smoke, consumer products and outdoor air; studies on the type and effectiveness of various schemes to reduce the indoor air con- centration of aldehydes.; and monitoring studies that use reliable analytical tech- niques to assess aldehyde concentrations in a broad spectrum of ~occupied indoor environ- ments." (page 12) "The specific effects of continuous ex- posure on other susceptible populations, such as infants, young children, pregnant women and the infirmed, are not known." (page 7) "The presence of environmental agents other than formaldehyde, smoking history, variability of health status, age, and genetic predisposition may modify responses to formal- dehyde. These factors have not been adequately evaluated. This makes it difficult to assess accurately the health risks attributable solely to formaldehyde." (page 6) "The human niutagenic and teratogenic potential is not known." (page 6) "Because of the incompleteness of the data,. no conclusions can be drawn about the carcinogenic, risks to humans exposed to f or- ma].dehyde." (page 7) "There is an urgent need for research to resolve several important questiOnS related to the health effects of formaldehyde." (page 16) PAGENO="0424" 420 "The effects of formaldehyde on nasal and lung defense mechanisms have not been well studied." (page 17) "Human epidemiologic investigations assessing the carcinogenic potential of for- maldehyde are lacking." (page 17) "Long-term effects of continuous low-dose ex- posure to formaldehyde are not known." (page 17) "Limited information is available on the interactions of formaldehyde with other air mutants." (page 18) Query: How can cost-effective regulation be realistically es- tablished while so many questions are unanswered? Mr. Chairman, I believe that a careful analysis of complaint data and information must be made. We hear various numbers tossed around which allegedly represent complaints of symptoms and health problems which are said to be caused by formaldehyde. However, from my previous testimony, I believe you can understand why I question the validity of many of these complaints because of the absence of any real data to show that formaldehyde, by itself, ex- clusively, was responsible for. the symptoms or problems. Please remember the p~rtial list of forty indoor air pollutants (not counting formaldehyde) to which reference was made earlier in my testinony. If any of these pollutants were present in the home, how can we say with any certainty that formaldehyde, alone, is re- sponsible for the alleged symptoms and health problems? Let's take a hard look at a rather common example of the so- called "proof" which is offered to show that formaldehyde in a man- ufactured home is responsible for health problems. PAGENO="0425" 421 --When the consumer is in the manufactured home, there are health problems -- when the consumer moves out of the home, the problems stop. Conclusion: formaldehyde in the manufactured home is responsible. Was formaldehyde the problem or was the problem one of "indoor air pollution" as suggested by many of the experts? I submit to you that the answer to that fundamental question is not known today. No adequate testing and research have been accomplished to make such a determination. Where did the consumer move? What indoor air pollutants were present in the dwelling into which the consumer moved? What indoor air pollutants (other than formaldehyde) were present in the manufactured home? Row do the aggregate number of pollutants compare between the manufactured home and the other dwelling? What are the differences in the air. infiltration and ex- change rates between the manufactured home and the other dwelling? Unless and until questions such as these are answered, any con- clusion that formaldehyde, alone, is the culprit is nothing but mere speculation and conjecture. Also, Mr. Chairman, I believe we need to examine the numbers ot complaints in relationship to the large number of American families that are purchasing and living in manufactured housing. For the five year period 1977 through 1981, 1,292,600 manufactured homes were constructed and sold in the United States. (Note: These are compilations of figures published by the Bureau of the Census in the February, 1982, "Construction Reports" reflecting the PAGENO="0426" 422 revised and updated totals from the National Conference of States on Building Codes and Standards.) Also, we estimate that today there are over 5,000,000 manufactured homes which are being occupied by approximately 13,000,000 persons. As mentioned pre- viously, manufactured housing is a major source of single family residences in the country. Now, how many complaints have there been? Of course, this is a difficult figure to pinpoint, but let's make a very liberal esti- mate of 5,000 (which I believe may well be 25% to 40% high). Assuming there have been 5,000 total complaints, that would only represent 0.1% of the estimated 5,000,000 manufactured homes which are being occupied. Looking at it another way, if the complaints were all related to manufactured homes which are five years old or less (ie., those produced and sold 1977 through 1981) the complaint. ratio would be 0.39%. Mr. Chairman, even if my estimates on complaints versus oc- cupied manufactured homes or versus homes purchased during the past five years were incresed by 100%, the complaints involving formal- dehyde or indoor air quality would still be at a ratio of less than one percent. Please do not misunderstand what I'm saying. I'm not suggesting that these complaints be ignored because of the very, very small percentage of homes involved in complaints; however, I believe that this extremely small complaint ratio must be a factor in any consideration concerning the regulation of formaldehyde emissions in residential structures. PAGENO="0427" 423 In the State of Texas, there have been 346 known, recorded complaints based on figures from the Texas Department of Health, the Texas Department of Labor and Standards, the Attorney General's off ice and surveys of retailers and manufacturers by. the Texas Man- ufactured Housing Association. Let's add 20% to this figure (for a total of 415) to be certain that the complaint figure is realistic. For the years, 1977 through 1981, 130,733 manufactured homes were sold in Texas, and we conservatively estimate that over 600,000 manufactured homes are occupied. Thus, on a five year homes pur- chased basis, the complaint ratio is 0.32%; on a homes occupied basis, the complaint ratio is 0.07%. Again, if we doubled the com- plaint ratios, they are still less than one percent. Mr. Chairman, we submit that the perceived problem is simply not nearly as great as perhaps some of the publicity in recent months would suggest. Now, Mr. Chairman, up to this point I've primarily presented a case for no regulation of formaldehyde because of the tremendous number of questions for which no adequate answers exist today. We must recognize the existence of these questions; and as recommended by the National Academy of Sciences, answers to these questions must be determined through substantial additional research. Also, it has been demonstrated that a very small percentage of manufactured homes -are involved in air quality complaints. PAGENO="0428" 424 Does that mean that regulation of fornaldehyde emissions in certain products should be delayed and put-off until all such questions are answered and all the research is completed or because the numbers of complaints are small? On behalf of the National Manufactured Housing Federation, as well as the Texas Manufactured Housing Association, I say eNols Initial regulation of formalde- hyde emissions from certain materials and products should begin as soon as possible. I am sure that some people will feel that this is an inconsis- tent position from the initial part of this statement; however, such is not the case. The position of NMHF is not only consistent, but represents the only practical initial solution to the resolu- tion of the competing public interests which have been previously mentioned. Let's take certain known facts which are not substan- tially disputed by the various medical and scientific opinions on the allegedly adverse health effects of formaldehyde. First, all of the experts seem to agree that levels of formal- dehyde in excess of 3.0 parts per million (ppm) cause various symptons and health problems. Some experts believe these to be temporary; others think the problems may be permanent. Second, the sensory irritant level for a substantial segment of the population seems to be in the range of 0.5 ppm to 1.2 ppm. Some experts think it is lower, but few, if any, of the medical and scientific experts believe that the sensory irritant threshold level is greated than 1.2 ppm. PAGENO="0429" 425 Third, the majorproducts or materials usedin the construc- tion of manufactured homes which emit formaldehyde are generally agreed to be the plywood paneling and the particleboard or plywood used in the floor and incabinets~and other built-ins. Carpeting, drapes, furniture, and many other items also emit formaldehyde, but most all experts agree that the wood products mentioned are the major sources of formaldehyde emission in manufactured homes. Thus, we favor regulation based on these known factors --~~ on the speculative opinions of a few -- when so many questions remain unanswered as pointed out by the National Academy of Sciences and when such a small percentage of homes are involved in complaints. This is not anew recommendation. In January, 1981, the National Manufactured Housing Federation filed a written petition with the U. S. Department of Housing and Urban Development urging that HUD should set and establish standards for the emission of formaldehyde from building products and materials, particularly paneling and particleboard. Copies of this petition have been sub- mitted to the Subcommittee, and I would incorporate such in this testimony by reference. Mr. Chairman, we repeat this recommendation today and em- phasize that a large segment of the manufactured housing industry supports reasonable regulation of formaldehyde emissions from building products and materials and further emphasize that we have supported such regulation, on the public record, since January, 1981. PAGENO="0430" 426 We also emphasize, Mr. Chairman, that we support standards for the emission of formaldehyde from wood products and materials used as components in the assembly of manufactured housing. We do not support, at this time, ambient air standards because of the great number of questions which still exist -- because of the substantial amount of research which still needs to be done -- because of the inconclusive evidence as to the threshold limit value -- because of the very, very small percentage of manufactured home occupants who claim to be affected adversely -- and last, because an ambient air standard, standing alone, applied to manufactured housing could, and probably would, result in the destruction of this industry and the elimination of this major *source of housing for American families. Please let me explain. Manufacturers of homes are merely assemblers of component parts. They do not manufacture and introduce into commerce any mew or different consumer products. Rome manufacturers merely buy products and materials produced by others and put such together and assemble such products and materials at a central plant or facility into a dwelling which can be transported to the homesite, installed, and occupied as a permanent residence. No formaldehyde is used by the home manufacturer; no formaldehyde is introduced into the home by the manufacturer. PAGENO="0431" 427 Thus, the manufactured housing industry is totally dependent on the suppliers of the various products and materials which are placed in the home. Our manufacturers use the sane products and materials which are marketed for use by all home builders, apart- ment and condoninium constructors, and by home owners for repair and remodeling. They do not use some "special" or "unusual" types of wood products or materials which are produced by the suppliers only for manufactured homes. Thus, Mr. Chairman, the manufactured housing industry is at the mercy of the giants of the forestry in- dustry who supply the various wood products and materials used in the assembly of the manufactured homes. We can only buy and use whatever wood products and materials they make. There are no formaldehyde-free plywood paneling and particle- board products available today. Let me repeat, that for emphasis: there are no formaldehyde-free plywood paneling and particleboard products available today. After that statement, the obvious question arises: why don't home manufacturers use other, or alter- nate, products and materials which do not contain formaldehyde? The answer is really simple, although perhaps not as obvious to many people as the question. Formaldehyde-free, alternate products are not readily available at this time for plywood and particle- board in a number of instances where these products are used. Two good examples are in the cabinets and various built-ins in the home along with the plywood or particleboard used in the subfloor of the home. PAGENO="0432" 428 If formaldehyde-free alternatives are, not availab.e, then why can't hone manufacturers use "low-emitting" wood products or materials? Are not these products available? The answer to this question obviously is completely dependent on what is meant by the phras.e "low-emitting". How much emission of formaldehyde from ply- wood paneling and particleboard is considered to be "low"? These questions (like the many raised by the National Academy of Sciences) have not been answered. Thus, home manufacturers cannot be sure whether or not these "low-emitting" wood products and materials are available. To demonstrate my point, let's look at the recent report pre- pared for HUD by Clayton Environmental Consultants, Inc. This technical report was produced from testing research performed pur- suant to Contract No. HC-5222, and it is dated March, 1982. In reviewing this report, you will have to be very careful to sort out the fact that the "higher" emission products used in the construc- tion of the homes are the so-called "low-emitting" products which are, to some extent, available today. The "low" emission products used in the construction of the test homes were a "special order" to meet the experimental design of the study. The Hardwood Plywood Manufacturers Association (HPMA) and the National Particleboard Association (NPA) have proposed standards for the production of "low-emitting" wood products. These proposed standards were, however, apparently the basis used to produce the "higher" emission products used in the testing. In the PAGENO="0433" 429 "Summary" of the Clayton Report, we find the following paragraph: "The two homes built of the lower- emitting materials showed consistently lower formaldehyde levels than did the other two homes. The formaldehyde level in the lower homes averaged slightly less than half the level measured in the higher homes. After 9 weeks of testing, the lower homes showed formaldehyde levels of 0.2 to 0.3 ppm, while the higher homes showed formaldehyde levels of 0.5 to 0.6 ppm." Thus, Mr. Chairman, the so-called "low-emitting" wood products which are available today only in limited quantities are inadequate (according to the Clayton report) to meet the study "target levels"~ of 0.4 to 0.5 ppm of formaldehyde. The manufactured housing indus- try submits that "low-emitting" products to achieve ambient air levels of consistency less than 0.6 ppm of formaldehyde are riot available today for use in all manufactured homes which are being constructed. The National Manufactured Housing Federation, as noted pre- viously, supports the establishment of emission standards for wood products and materials by RUD. We want all home manufacturers (and homebuilders, also) to play under the same set of rules and regula- tions, and these manufacturers want the regulatory establishment of emission standards so that they will know what is meant by "low- emitting" products. We want the plywood, the paneling, and the particleboard industries to be required to meet reasonable emission standards so that our industry can purchase with certainty wood products which meet these standards. Without such products and materials standards, the home manufacturer is faced with a 97-153 O-82----28 PAGENO="0434" 430 virtually impossible task of knowing the aggregate formaldehyde emission potential of the various wood products used to construct the homes. An ambient air standard alone will not change this situation; it will only result in creating substantial potential liability for the hone manufacturer without any basis for the manufacturer to have recourse against the various wood products suppliers. The result of this, Mr. Chairman, I submit will be a substantial reduction in the number of affordable homes which will be available to American families; such is~ not in the public interest. Mr. Chairman, the manufactured housing industry is concerned about the questions which exist in connection with the possible ad- verse effects on the~ health and safety of the occupants of our hones from formaldehyde in the indoor air. We are very concerned about indoor air quality generally as it may affect the live- ability, the habitability, of manufactured homes. We eagerly solicit the help of the Congress and of HUD or other appropriate government agencies in resolving the many questions which currently exist in connection with indoor airquality. Obviously, it is in our own best interest, as well as that of the public, to construct safe. and durable housing. We believe that our industry is doing this today with the products and materials which are generally available in the marketplace. PAGENO="0435" 431 I suppose that the Congress, in the interest of public health and safety, and assuming no constitutional restrictions, could re- quire that all dwellings be constructed of steel, concrete, and glass. This would undoubtedly eliminate the alleged "formaldehyde problem", and it would also undoubtedly upgrade the fire safety of the dwelling. However, very, very few families would be able to afford such residences; and, of course, the manufactured housing industry would be eliminated. However, such a ~solution" would certainly not balance the tremendous public need for afforable housing. Future research may dictate the need for the elimination of formaldehyde from building products and materials as well as the many thousands of other consumer products in which it is used. Future research may conclusively establish certain threshold limit value parameters. However, the evidence now available from the re- search which has been completed is not conclusive. The best, the most logical recommendation today is the one made by the National Academy of Sciences that formaldehyde in the indoor ambient air should be kept to the lowest practical level. I submit that such level today is the level which results from purchasing the lowest emitting wood products and materials which are currently available. By ~available", Imean readily available in sufficient quantity for purchase by all home manufacturers and builders for the construc- tion of all residential dwellings. PAGENO="0436" 432 Quite frankly, Mr. Chairman, I don't know what such emission level is. Only the chemical companies which make the formaldehyde based resins and the forestry. and timber companies which use the resins in making the various wood products can answer that question. Today, some of the wood products suppliers advertise Rlow..emittingll materials -- but they will not give the home manu- facturers any warranties or guarantees as .to the long term formal- dehyde emission performance of. these products and materials. Thus, we desire .regulatory standards to establish what slow-emitting" means. These standards should be set by BUD so that they will be preemptive of differing state standards in order to allow our in- dustry to continue to build safe, durable homes to a single national standard so that affordable manufactured housing will con- tinue to be available in the future to the largest possible number of American families. I thank you for the. opportunity to appear on behalf of the National .Manufactured Housing Federation, and I will be glad to attempt to answer any questions, Mr. Chairman, which you and other members of the Subcommittee might have. Respectfully submitted, for the National Manufactured Housing Federation PAGENO="0437" 433 Mr. ROSENTHAL. What did you think of the testimony of the den- tist from New Jersey yesterday? Did you hear his testimony? Mr. EHRLE. I only heard part of it, sir. Mr. ROSENTHAL. He has a 28-year-old wife who had an operation on her nasal passages. Did you have any thoughts about that? Mr. EHRLE. Yes, sir. I do. I think that specifically ties into what I am saying now. I think he is very sincere, and I think his wife is as well. Obviously, she has had a medical problem. They are not making it up. It is not some conjured up story. It is real. I am simply saying that I am not at all certain-and based on the testimony of experts today-that formaldehyde alone was the cause of that. Mr. ROSENTHAL. It struck me as extraordinarily coincidental that, after they moved into the new home and had formaldehyde insulation put in, all their troubles started. Mr. EHRLE. That is correct, but remember what I was saying. UFFI provides a very tight barrier for air infiltration inside an ex- isting structure. You see, the walls breathe. There is air exchange and air infiltration in structures, unless you wrap them in plastic. That is what happens in manufactured homes today. They are vir- tually wrapped in plastic. Mr. ROSENTHAL. His is not a manufactured home. His is a tradi- tionally built home. Mr. EHRLE. That is right, but is it the UFFI, or is it the sub- stances which are sealed in. Mr. ROSENTHAL. That would have happened in their old house. It was just such a coincidental thing. After they moved into the new house with formaldehyde, that is when their troubles started. Mr. EHRLE. I understand, but it is trapping not only formalde- hyde. It is trapping the toluenes and all of the other substances. Mr. ROSENTHAL. You mean it is formaldehyde plus the rest. Mr. EHRLE. Yes, sir. Mr. ROSENTHAL. In their previous house they had the rest, but they did not have the formaldehyde. Mr. EHRLE. No, sir. They did not have the rest in those concen- trations because they did not have the trapped environment in the other house. Mr. ROSENTHAL. In the new house they could have turned on some kind of heating or cooling system to keep the air going. Mr. EHRLE. No, sir. If your heating system is using indoor air and is heating and returning to the indoor air-- Mr. ROSENTHAL. It is recirculating the same air. Mr. EHRLE. It certainly is. That is typical of a site-built structure. The heating in it does not provide air exchange rates normally. Mr. ROSENTHAL. If they opened the windows, I presume, it might have helped. Mr. EHRLE. Yes, sir. Mr. ROSENTHAL. I assume-there is no sense in assuming. I see the problem in manufactured homes, but in the home which this fellow has, the coincidence is incredible. Presumably, they were normally healthy young people. They were not old or babies. The fact that it had to do with the nasal area made it so stark in con- nection with the other medical testimony. It would be an incredible coincidence, it seems to me. PAGENO="0438" 434 Mr. HOWLETT. Mr. Chairman, may I respond too? Mr. ROSENTHAL. Yes. Mr. HOWLETT. Thank you. I think it is a tragedy that someone that young developed nasal cancer. There are about 200 to 250 cases of nasal cancer reported in this country every year. There have been a substantial number of studies done on nasal cancer in this country. It is interesting, I think, to point out that there are regions of the world, particularly southern provinces in China and their descendants, where people have higher rates. For example, if you look at cancer rates in San Francisco, there is a larger Chinese-American population, and you see similarly high nasal cancer rates as you do in southern China. There are other people who are genetically predisposed, unfortunately, to nasal cancer, such as people who have a longstanding sinusitis con- dition-- Mr. ROSENTHAL. I accept all that. Mr. HOWLETT. The epidemiological studies-and now there are 10 in the literature-have looked at workers exposed for at least 15 years, sometimes for as long as 40 years of exposure, at levels of 2 to 4 parts per million if you go back in time. They are not seeing that kind of a result. It is an incredible coincidence. I agree with those words of yours, but I think that it is important that this issue be examined, as the epidemiological studies are attempting to do, in a case-controlled, scientific manner to find out whether there is a relationship. Right now, as the ACS and NIOSH have indicated, there is no evidence of human cancer related to formaldehyde. Mr. EHRLE. Let me finish quickly, if I may, Mr. Chairman. I want to mention and make reference to the National Research Council of the National Academy of Sciences report on aldehydes. There are substantial sections in the volume which relate to form- aldehyde. I. mention this in the written statement. I will not read them. I *have a page and a half of questions. If you will go through the summary, in particular, Mr. Chair- man, you will find that it is an outstanding report. This should be the Bible today on formaldehyde. Nothing has really significantly changed since this report was presented. Other studies have begun, but none have been completed. This report addresses the Fisher rat situation as well. The report raises serious questions relative to the scientific evi- dence and establishes a list of additional research which needs to be done. Part of what Mr. Howlett referred to are the recommendations for research-- Mr. ROSENTHAL. Let me interrupt you because we really are under a tremendous time constraint. I appreciate your indulgence during this day. Is it correct that the standards which your industry and other in- dustries are working on would apply to the manufactured product in the factory rather. than the assembled product on the site? Mr. EHRLE. No, sir. There is a correlation of the ambient air. There are engineering correlations relative to the products them- selves and their off-gassing and the-- PAGENO="0439" 435 Mr. ROSENTHAL. You heard the dialog we had with the gentle- man from HUD, Mr. Abrams, today. The proposed standards which the industry is recommending and which HUD may adopt will have to do with the testing for formaldehyde of the manufactured product at the factory. Is it fair to assume that the formaldehyde emission will increase when they are put together in a manufac- tured home? That is my question. Mr. EHRLE. No, sir. It is not reasonable to assume that it would increase when they are put together in a home. If the emission rate of one piece of board is 0.5, and another piece of board is 0.4, your emission rate for the home will be 0.5. Mr. ROSENTHAL. On page 16 of your statement-I am sympathet- ic to your statement. You say: " * * * and last, because an ambient air standard, standing alone, applied to manufactured housing could, and probably would, result in the destruction of this indus- try and the elimination of this major source of housing for Ameri- can families." I understand that, am sympathetic toward it, and so forth. I am also very sympathetic toward the people who have either real or perceived problems. You do not support an ambient air standard because of the number of questions which still exist. I am trying to understand. The standard you support does not consider what happens to all of the plasterboard or plywood after it is put together in the manufac- tured house. Is that not correct? Mr. EHRLE. No, sir. That is not correct. Mr. ROSENTHAL. Tell me where it is incorrect. Mr. EHRLE. The product standard would be the standard at which the product itself would contain and would emit formalde- hyde vapor. Mr. ROSENTHAL. Do you mean at the factory? Mr. EHRLE. It would mean there or later. Mr. ROSENTHAL. That is the big distinction. Tell me how you devise a scheme which takes into account there or later. Mr. EHRLE. Mr. Howlett can, I think, more accurately answer this. There are definite correlations. The emission rate will not change. Mr. ROSENTHAL. As a layman, it seems to me that it changes if I have 1 board or if I put 40 of them together in an enclosed environ- ment. It has to change by a factor of 40 or maybe considerably more. Am I wrong? Mr. HOWLETT. You were right up until you got to the factor of 40. It is not a totally additive effect. Let me back up a little bit. The reason why I think it is impor- tant to test the product at the point of manufacture is this. If you have confidence in the ability to correlate those tests to what you see in an actual home construction, which we have done in the study which was conducted jointly with HUD, you can establish that link. It is better to test at the factory. If it goes over the qual- ity control parameters, you can stop shipment then, rather than having it wind up in the marketplace. Mr. ROSENTHAL. I understand that. Tell me what mechanism you have devised-I am not sure I can understand it-to measure and PAGENO="0440" 436 develop a correlation between the tests you do at the factory and the tests you do after it becomes a manufactured home. Mr. HOWLETT. It has been a rather long and complicated process. I believe that we have done it in record time. First of all, you had to develop a verifiable and reproducible test method. Formaldehyde is a very, very reactive substance. You just do not throw it out, suck air through it-that took time. Mr. ROSENTHAL. Do you have any engineering studies? Mr. HOWLETT. Yes. We do. Mr. ROSENTHAL. Could I understand them, or could I be pre- sumed to understand them? Mr. HOWLETT. We presume you could understand them. Mr. ROSENTHAL. Do they show how you do that? Mr. HOWLETT. Yes. The voluntary industry standards are predicated upon anticipat- ed loading rates. You expect that a home will have a floor. You expect a home will have walls. You assume that it will be made of building products which will be made of formaldehyde. We have taken that into account in developing the standards. Those two in combination will not run you over what Minnesota and Wisconsin have said are acceptable ambient formaldehyde levels. That is not to say that the introduction of some additional mate- rial, not covered by these two standards-we are only talking about walls and floors-cannot run it over. Mr. ROSENTHAL. I accept that. Mr. HOWLETT. That is also to say that we are testing both at the factory, in the large environmental chamber, and the field units which were tested, that is, the prototype units, were also tested under specified conditions of ventilation and temperature. As Mr. Ehrle pointed out, you can have very, very low ventila- tion rates. There is a very critical ventilation effect built into the test. Mr. ROSENTHAL. How many onsite units did you test? Mr. HOWLETT. There have been a number of studies ongoing. The Clayton study, which was just completed, involved random-sample testing of, I believe, over 250 mobile homes. The prototype testing involved two pair of homes built with high-emitting materials and a pair built with lower emitting materials. The assumption was that, if you built with lower emitting mate- rials, the ambient formaldehyde level would be lower. That as- sumption proved to be correct. Second, we tested that in static tests and dynamic environmental chambers back at the factory. We predicted what the home level would have been. When the home was constructed and actual levels were measured over a 60-day period, they correlated very, very well. Mr. ROSENTHAL. How did you make the predictions? Mr. HOWLETT. The environmental chamber is a 1,000-cubic-foot chamber. It is like a big, walk-in refrigerator or cargo container. It is that size of box. You load in the boards at the loading rate. You put in a proportionate number of particle board decking or wall paneling at the same rate as if you were to build a home. A single- wide mobile home is seven times the size of the chamber. PAGENO="0441" 437 You introduce an air change at a fixed rate-one-half, one, or whatever the standard calls for. You calibrate the temperature to 76 F. You have a dehumidifier. Mr. ROSENTHAL. Do you put in the same number of boards as would make up a manufactured home? Mr. HOWLETT. It is at the same loading rate. For decking, it is 0.15 square feet per cubic foot of airspace. For the hardwood ply- wood paneling which goes into walls, it is 0.32 square feet per cubic foot. Mr. ROSENTHAL. How many boards would you put into an aver- age-if there is such a thing as an average size-manufactured home. Mr. HOWLETT. I will take a rough guess. A single-wide mobile home would probably have 1,000 square feet of decking and 2,000 square feet of wails. Mr. ROSENTHAL. What about the ceilings? There is a total of 3,000 square feet. You measure that at the fac- tory under simulated conditions. Mr. HOWLETT. That is correct. Mr. ROSENTHAL. What is the final off-gassing-formaldehyde rate in a typical manufactured home using your standards? Mr. HOWLETT. If you look at the Clayton study, you are seeing- in newly occupied mobile homes, they were measuring an average level of around 0.4. In the older occupied homes, I think it was down around 0.2. In a random sample of mobile homes in Wiscon- sin, they measured 0.16. Mr. ROSENTHAL. Is not 0.5 a kind of caution point? Mr. HOWLETT. Formaldehyde emissions drop over time. They will drop off rather rapidly. Mr. ROSENTHAL. They did not in the one we tested outside. Mr. HOWLETT. That was tested under two conditions which I do not believe necessarily simulate normal conditions of occupancy, one being the 90 degrees, and one is that the heating, cooling, and ventilation systems were not hooked up to electricity. Mr. ROSENTHAL. It does get to be 900 in some parts of the United States. Mr. HOWLETT. Normally, people will be going in and out of the home, or whatever. You did not also measure for oxygen levels or carbon dioxide levels. There were a lot of people in the unit. When you test for other compounds, sometimes you can be surprised what-- Mr. ROSENTHAL. However, people in the unit would make it worse, I suspect. My question is this. Has not 0.5 become a point of concern? Is that true? Mr. HOWLETT. The Minnesota Department of Health, after exten- sive hearings and review of all of the records which were submit- ted, concluded that 0.5 would protect the citizens of Minnesota in conventional and mobile home construction as an appropriate expo- sure level to formaldehyde. Mr. EHRLE. Mr. Chairman, let me point out too-- Mr. ROSENTHAL. The doctor who testified from Minneapolis-I thInk he was from Minneapolis-seemed to be more comfortable with 0.1 rather than 0.5. PAGENO="0442" 438 Mr. HOWLETT. There were others who testified from Minnesota and Massachusetts to the contrary, the State regulations were based on all of the testimony which they heard. Mr. EHRLE. Let me point out too, Mr. Chairman, that there was a conflict in Dr. Westgate's testimony yesterday. He did recommend 0.1, but you heard him at another time say that the standard for residences should be no more than one-third of that for industry. There was a slight conflict in his testimony. If you take the level of 3 parts per million, the OSHA industrial standard, or if you take the 2 parts per million which some of the States can use by reference, and divide that by 3, you come out with 1.0 part per million, and obviously, 0.67. I do not understand where 0.1 comes from in Dr. Westgate's tes- timony. He said it should be not more than one-third of the indus- trial level. Mr. HOWLETT. Mr. Chairman, may I respond as well? The figure of 0.1 part per million has had three sources. It has been a number which has circulated over the last 3 years or so at both the State and Federal levels. It comes, in one place, from the lower level of detectability of the NIOSH method. It is sensitive down to 0.1, which basically is a zero-exposure rationale. You can also take a mathematical factor of the workplace, as Mr. Ehrle indicated. They have taken one-tenth of the NIOSH recommended 1.0 ppm and ar- rived at 0.1. That is also how the Europeans arrived at what have been Euro- pean guidelines, which are 0.1 and 0.12. I think, as the German study amply indicates, a guideline in Europe is not like a standard or a regulation as here in the United States. In fact, the reference to that 0.1 German standard-they have done no testing, which we can find, in the published or unpublished literature correlating--- Mr. ROSENTHAL. Was that for the home or the factory? Mr. HOWLETT. That was for the home. Mr. ROSENTHAL. What did you think of Dr. Newhouse's testimo- ny? Mr. HOWLETT. I think that Dr. Newhouse's testimony is consist- ent with the National Academy of Sciences' report and the two re- ports on formaldehyde. I think it is consistent with a lot of the other testimony which we heard in Wisconsin, Minnesota, and a number of other areas through CPSC on acute effects. That is, if there is a threshold somewhere around 1 ppm and you get it down to around a half, you are not going to recognize the odor. There are, however, some hypersensitive, hypersusceptible people who will react to lower levels. I think that the NAS document points out: one, that the mecha- nism is not understood; two, that it is not thought to be a large pro- portion of the population. In fact, it is thought to be extremely small. Mr. ROSENTHAL. Have you heard Dr. Newhouse testify before? Mr. HOWLETT. I heard Dr. Newhouse at the conference in Canada.. Mr. ROSENTHAL. Where was that? Mr. HOWLETT. It was sponsored by some group in Toronto. It was CORPUS, which is like Government Enterprises. They hold profes- sional seminars. PAGENO="0443" 439 I was also invited to present a paper. Mr. ROSENTHAL. On what subject was your paper? Mr. HOWLETT. It was on formaldehyde. Mr. EHRLE. Mr. Chairman, we want a standard. The manufac- tured housing industry wants a standard. We think it is the Feder- al Government's obligation to provide that. Mr. ROSENTHAL. You want the Federal Government to adopt an industry standard. Mr. EHRLE. It may be the right one. I do not know. Mr. HOWLETT. I am not saying an industry standard. Mr. ROSENTHAL. You mean an industry-recommended standard. Mr. EHRLE. I am saying that the people of this country deserve to know what the safe levels of formaldehyde are, and I think the Federal Government has that obligation. The scientific community can argue before the appropriate agen- cies-or it may be Congress-what level it should be. I am simply saying that, on behalf of the manufactured housing industry, we do not like to be in a position of HUD's regulating the moisture con- tent and not telling us what formaldehyde content ought to be in the building products. Mr. ROSENTHAL. You want to know what it should be. Mr. EHRLE. Yes, sir. Mr. ROSENTHAL. If you are told what it should be, can you deal with it? Mr. EHRLE. I hope it would be a standard which the wood prod- ucts folks could adhere to so that we could buy products. You can build houses, Mr. Chairman, out of steel and concrete. You can make them firesafe almost totally. You can eliminate for- maldehyde, but nobody can afford the house. There are economic considerations. Our industry is not concerned about the economics of $100, $200, and so forth. That has not been a consideration, but we do not know what low emission means. We do not know what standards are safe. The Federal Government has undertaken the regulation of our industry, and we think the Federal Government has the re- sponsibility now to set the standards. Mr. ROSENTHAL. Do you mean with your advice and consent or without your advice and consent? Mr. EHRLE. I hope we would have an input, but again, Mr. Chair- man-- Mr. ROSENTHAL. It seems to me that you have had pretty good input up until now. Mr. EHRLE. The process seems to work. I have a great of faith in the democratic process which we have, both legislatively and regu- latorily. I do not agree with the end result every time, but I have a great deal of faith in the system. However, the system needs to work in this connection because of the publicity, as Dr. Newhouse mentioned. People are somewhat frightened. They need some basis on which to know whether their fears are justified or not. We cannot tell them today. My industry cannot. Mr. ROSENTHAL. Have you ever met Dr. Newhouse, Mr. Howlett, other than at the seminar in Canada? Mr. HOWLETT. No. PAGENO="0444" 440 There were also participants from the provincial government and the national government, which were involved in the regulation of theirs, who were also invited to speak. Mr. ROSENTHAL. Mr. Hiler? Mr. HILER. Thank you, Mr. Chairman. if I may direct a question to Mr. Ehrle, when you say that there need to be industry standards, are you orienting that toward prod- uct standards, ambient air quality standards, or what? How would such standards be applied? Would they apply to site-built homes as well? Mr. EHRLE. 1 think it obviously needs to be a product standard, set both by HUD and by the Consumer Product Safety Commission, so that it would apply to all building material. For example, if building materials of high rates of emission are not safe, then they are not safe for remodeling. They are not safe for all of the various applications within site-built structures as well as manufactured homes. We need a product standard which would apply to the product itself. Obviously, the ultimate ambient air level of formaldehyde is the consideration for which the product standard is set. If there were no correlation between product standard and ambient air levels, then a product standard would not do it. However, as Mr. Howlett testified, there is accurate engineering data, and some testing has been completed. Additional testing should be done, but there are data to show the correlation between product emission rates and ambient air concentrations. Mr. HILER. Even if there were homes constructed, which were down to 0.05 or 0.1 ppm, which I suppose is a possibility, it appears that there will still be people who are hypersensitive to formalde- hyde. They are probably hypersensitive to cigarette smoke as well, or any number of other irritants. People with that hypersensitivity probably should not live in a manufactured house. Probably, in any site-built home, they would have to be extraordinarily careful to have all natural materials and furnishings. Is there any way in which we can prevent these people from get- ting into a hyperallergic situation? Mr. EHRLE. That is extremely difficult. First of all, they are such a small, small portion of the population. For example, people with allergies, particularly to house dust, house mites, and so forth, should not have carpeting in their homes. It is a major source of house dust, house mites, and other allergens. Many times people simply do not know what their allergies are. It is very difficult to warn them like this: "If you have a hypersen- sitivity, do not buy this product." They will not know whether they are or are not many times. I cannot answer the question. I do not know how that might be possible. We are fortunate, I think, that that is such a very small percent- age of the population. Mr. HILER. The biggest question will come in setting the thresh- old level of sensitivity. You are saying that it is possible for the in- dustry to live within 0.5 ppm? Mr. EHRLE. I do not know what the level should be. The manu- factured housing industry simply takes the position that we want PAGENO="0445" 441 to buy the product which has been certified by the Federal Govern- ment in this connection, with reference to formaldehyde emissions, which are safe. We would like very much to be able to do that. If the Federal Government decides to get out of the construction code and standards business for manufactured housing, that is a decision which will have to be made by the Congress, but as long as the Federal presence is there, then I think is incumbent upon the regulators to tell us what to do with reference to formaldehyde. Mr. HILER. Mr. Ehrle, you have mentioned several times now that you are in favor of the Federal Government setting the stand- ard. I have become somewhat concerned about that. It is not neces- sarily that the Federal Government should not have that responsi- bility, but given the thrust of the testimony from the three wit- nesses today, and in trying to extrapolate from what the three wit- nesses said yesterday, it appears to me that the Consumer Product Safety Commission moved in a fashion which may not have been in tune with orthodox, scientific, epidemiological studies. Now, appar- ently, HUD is getting ready to accept what CPSC has done as a basis for their moving forward. I have great concern that we may be proceeding in the absence of sufficient evidence. Mr. EHRLE. I have great concerns with reference to what the level should be. Let us take Dr. Newhouse's testimony. With reference to manu- factured housing, you can take his testimony and say that, at 0.5 ppm and above, even Dr. Newhouse would say it is not a safe level, I think. Maybe it was 0.6 ppm or between 0.5 and 0.6 ppm. My point is this. There is a consensus of opinion that at some levels it is either intolerable, or it is not safe, or whatever. I think we need the Federal Government to establish what the parameters are for the public. I wish that were not necessary, but it has become necessary be- cause of the publicity related to formaldehyde. Mr. HOWLETT. May I respond briefly to both questions you have just asked? In terms of product performance standards and whether they should come from CPSC and/or HUD or not, it seems to me that a lot depends upon what your exposure level is. Certainly, there has been a substantial number of tests and studies now reported on ex- posure levels in conventional houses, where you have buildings product used which have UF resin. We are seeing levels reported, whether they are U.S. or Canadian studies, in a 0.03 to 0.06 ppm background level range. All the control programs are not without their costs and encum- berances. It seems to me that, when one wants to put one of those programs into place, it ought to be predicated on a need. We clearly support product performance levels for products which are going into the manufactured housing industry because there is a lower ventilation rate and, typically, a higher loading of formaldehyde in the materials. We believe there has been a need established. We have developed performance standards, and we support their incorporation. They are not developed solely by industry. They are not some- thing which was cooked up in a back room by a bunch of entrepre- PAGENO="0446" 442 neurs and robber barons. The standards were developed to use en vironmental chamber tests, predicated on a target ambient level which was established in the States of Wisconsin and Minnesota by the public health departments there. Mr. HILER. I yield back the balance of my time, Mr. Chairman. Thank you very much. Mr. ROSENTHAL. Thank you both very much for very enlighten- ing and informative testimony. Mr. EHRLE. May I make one inquiry, Mr. Chairman? Mr. ROSENTHAL. Yes. Mr. EHRLE. If you will recall the testimony of the Lovejoy family yesterday, Fleetwood Enterprises built their home. I contacted Fleetwood last evening. They were very concerned because Fleetwood indicated, at least to me, that with a cursory look they could not find, ever, a complaint concerning formaldehyde or indoor air quality. I would like the permission of the chairman to allow me to obtain even a sworn statement from Fleetwood to insert into the record, simply because it is a responsible manufacturer of homes. They were concerned about the fact that there was an inference that they had not responded. I would like to be able to insert-- Mr. ROSENTHAL. Without objection, the material will be included in the record at this point. [The material follows:] PAGENO="0447" 443 TEXAS M ~OJI~ACTUI~ID) HOUSING ASSOCIATION P.O. BOX 15343 * AUSTIN, TEXAS 78761 * AMERICAN FOUNDERS BLDG. * SUITE 210 * 512/459-1221 TCONGRESSMAN BEN ROSENTHAL June 17, 1982 RECEIVED DOC# FEC#_... The Honorable Benjamin S. Rosenthal L!~CODE._. Chairman on House Subcommittee on Commerce, Consumer, Monetary Affairs 2372 Rayburn House Office Building Washington, D.C. 20515 Dear Mr. Chairman: First, let me express to you my appreciation for being included on the panel for your recent subcommittee hearing on formaldehyde. I read, with interest, about your introduction of the "Formaldehyde Victims Compen- sation Act of 1982'. An accurate testing assistance service could be particularly valuable to the consumer. Second, thank you for allowing me to insert a state- ment from Fleetwood Enterprises, Inc. (a very reputable company which is currently the number one manufacturer of mobile/manufactured homes in the country) concerning the Lovejoy complaint. However, because of the high probability of imminent litigation, Fleetwood's attorneys felt that the filing of a statement in your hearing record might raise ethical questions. Thus, in an abundance of caution for the observance of high ethical legal standards, they have respectfully declined the considerate opportunity to insert a statement. Again, thank you very much. Very truly ours, Will Ehrle WE : df PAGENO="0448" 444 Mr. ROSENTHAL. The subcommittee stands adjourned. [Whereupon, at 5 p.m., the subcommittee adjourned, to recon- vene subject to the call of the Chair.] PAGENO="0449" APPENDIX CORRESPONDENCE AND MATERIAL SUBMITTED FOR THE HEARINGS Consumer Federation of America :~T'~'~'~' *f~:::~ May 18, 1982 Representative Benjamin Rosenthal House Subcommittee Ofl Commerce, Consumer, and Monetary Affairs Room B 377 Rayburn House Office Building Washington, D. C. 20515 Dear Congressman Rosenthal: Consumer Federation of America (CFA), the nation's largest con- sumer advocacy organization, would like to outline for you our position on the issues which have emerged from the Consumer Pro- duct Safety Commission's decision to ban urea formaldehyde foam insulation. On February 22, 1982, after six years of intensive investigation, the U. S. Consumer Product Safety Commission (CPSC) voted over- whelmingly to ban the manufacture and sale of ~~ea_formaldehyde foam insulation(UFFI) in residential dwellings. The Commission's decision was based on the "unreasonable risk" to the health and well being of American home dwellers posed by outgassing from ~rea-forma1dehyde fumes. The CPSC decision represents the tip of the formaldehyde iceberg. According to industry estimates, products containing formaldehyde account for eight per cent of the entire U. S. Gross National Product. UFFI accounts for only 6.3 per cent of the overall urea- formaldehyde production. 65.6 per cent of the urea-formaldehyde produced in the United States is used in the manufacture of ply- wood, fiberboard, particle board, and other pressed-wood products. These products are used extensively in new home construction, mobile home construction and home rehabilitation and remodeling. 1314 14th Street, N.W. * Washington, D.C. 20005 * (202) 387-6121 (445) 97-153 O-82--29 PAGENO="0450" 446 Formaldehyde is a ubiquitous substance. It is presont in scores of consuraer products, from draperies and carpeting to insulation andtoothpaste. Its concentration and outgassing from insulation and pressed-wood products have made it the subject of study and concern of Federal and state officials charged with protecting the public health and welfare. Its discharge from other consumer products is the subject of a study soon to be released by the CPSC. Our concerns about reduction of consumer exposure to formaldehyde center around three main points: 1) that assistance be provided to consumers who experience adverse health effects caused by urea-formaldehyde foam insulation in their homes; 2) that efforts be made to reduce formaldehyde emissions from other consumer products, particularly such pressed-wood products as plywood, particle board, and fiberboard; 3) that regulatory efforts be made by the U.S. Department of Housing and Urban Development (HUD) to reduce consumer exposure to formaldehyde in mobile homes to an ambient air level less than .1 ppm. 1. Since banning the manufacture and sale of urea-formaldehyde foam insulation in February of 1982, the CPSC has received approximately 10,000 phone calls and letters from people concerned about exposure to formaldehyde in their homes. A recent ABC News 20/20 program on the formaldehyde health threat generated 80,000 requests for additional information. Unfortunately, the ban of UFFI did not help those people who already have that product in their homes. On the contrary, it served in all likelihood to reduce the value of peoples' homes on the marketplace by up to 25 per cent (industry figures). Real estate experts estimate the cost of pulling UFFI out of peoples' homes would run into thousands of dollars, a price well beyond the reach of most affected households. We propose that legislation be drafted to ensure legal recourse for victims of poisoning from urea-formaldehyde foam insulation already in their homes. Consumers face an increasingly difficult time receiving redress from industry for the physical and financial hardships caused by UFFI. This is particularly significant in light of the legal morass that has developed in connection with litigation surrounding other toxic chemicals (i.e. asbestos), and the regressive product liability legislation now being considered by Congress. We propose legislation that would render the formaldehyde industry legally responsible for removing UFFI from any home PAGENO="0451" 447 where the occupant(s) has experienced adverse health reactions attributable to formaldehyde exposure. This legal liability would protect new occupants of a UFFI-insulated hone in the event the home is sold, for a fixed period of time, not to excede ten years. If the new occupant(s) experience adverse health effects, the industry would be responsible for removing the foam and restoring the house to its original condition. This would have the effect of relieving sellers of the UFFI- insulated home from the burden of financial loss in selling their home. The proposed legislation is based on the Massachusetts regulatory model. It would extend liability to the manu- facturers of urea-formaldehyde if the installers or manufacturers of the UFFI are no longer in business. I.t would in addition establish legal liability of the chemical manufacturer to consumers for personal or property damages resulting from exposure to UFFI. 2. Action must be taken to reduce formaldehyde emissions from other consumer products emitting the toxic gas. Studies by the National Academy of Sciences, and consumer complaints to the CPSC and the citizens' group, Save Us From Formaldehyde Environmental Repercussions (SUFFER), have pointed to a formaldehyde outgassing problem in particleboard, plywood, and other pressed-wood products at least as toxic to consumers as threats from UFFI. Outgassing from these products is the result of their manufacturing process. Wood chips, sawdust, and other wood products are compressed by high temperature and pressure, with urea-formaldehyde resins used as a glue to keep the mixture in place. Free-floating formaldehyde is a natural result of the use of urea-formal- dehyde in this process. Through time, dependent on heat and humidity, this formaldehyde outgasses into the environment. The CPSC is currently holding discussions with manufacturers of pressed-wood products in an effort to develop voluntary standards for the safe emission of formaldehyde. We believe that a .05 ppm product standard is required to ensure adequate protection of consumer health and safety in their homes. This figure is based on three factors: a. Scientific evidence that typical homes have a background formaldehyde ambient air level of .05 ppm (emissions from carpeting, drapery, and the scores of other products containing the chemical); b. Experts estimate that many people experience adverse PAGENO="0452" 448 health reactions to formaldehyde at concentration levels of .1 ppm (Although reactions may occur at even lower levels, and the National Academy of Sciences has stated there is no known safe level of exposure to formaldehyde); and c. The cumulative effect of formaldehyde concentrations on human health. Scientists have found, and industry spokesmen concur, consumer exposure to multiple sources of formaldehyde in the home result in amplified health impacts, the total exposure being greater than outgassing levels from each individual source. Pressed-wood products, used for home remodeling, rehabilitation, or furnishing, simply add to the existing background levels. The result, combined with reduced air circulation caused by energy conservation measures, can be indoor ambient levels well beyond any healthful range. 3. The U.S. Department of Housing and Urban Development (HUD) is currently developing standards for formaldehyde concentration in mobile homes. Mobile homes represent a particular formaldehyde health threat due to their high ratio of pressed-wood products to air space in the sealed-off homes. This problem has been heightened since HUD implemented its energy conservation standards for mobile homes in 1976. CFA believes that an indoor ambient air standard of .1 ppm is the highest acceptable level of consumer exposure to toxic formaldehyde inside mobile homes. HUD is seriouslly considering an industry-sponsored .4 ppm ambient air standard, a position which has taken even industry representatives by surprise. HUD's adoption of this high standard would seriously threaten the health and safety of mobile home dwellers. In conclusion, consumer exposure to formaldehyde is a growing national health threat. We praise CPSC's actions in banning UFFI, encourage the Commission to adopt a .05 ppm emission standard for pressed-wood products, and wait the Commission's studies on the outgassing of formalde- PAGENO="0453" 449 hyde from other consumer products. We call on the Department of Housing and Urban Development to set reasonable ambient air standards of .1 ppm for mobile homes, and we call on Congress to develop effective means for consumers to gain redress directly from industry members to cover the financial burdens of reducing the formaldehyde threat in their homes. Thank you very much. Sincerely, `I I'- ~ c~ Anne C. Averyt, Product Safety Advisor ~ ~ David I. Greenberg~,- Legislative Director PAGENO="0454" 450 ~iL~ NATIONAL ~ HOMEOWNERS ~ ASSOCIATION 1906 Sunderland Place, N.W. Washington, D.C. 20036 May 10, 1982 CONGRESSMAN BEN POSENTHA1~ RECE!V~ rc~c Hon. Benjamin S. Rosenthal Chairnan, House Government Operations ~y ~ Committee's Commerce, Consumer and Monetary Subcommittee PARA .....~ B377 Rayburn Mouse Office Building - Washington, D. C. 20515 FILE CODE. Dear Mr. Chairman: The National Homeowners Association respectfully subnits the enclosed testimony for the Commerce, Consumer and Monetary Affairs Subcommittee's consideration during deliberations on urea formaldehyde insulation. Thank you for the opportunity to make NHA's view known. Sincerely, ecutive Director JLW: pm Enálosure PAGENO="0455" 451 The dotional Homeowners Association, Washinctort, 1)-C., an (rga]1zation representing the interests of America's hocaotoexs, aepreciotes this oppurtunity to subuit the following testimony rcgnrding rcmoLic:s for oaaers of homes insulated with urea iormaldeliyde fonia (UF foam). dNA feels that by enacting tax credits for installing residential insulation and approving standards for urea formaldehyde use, the federal government encouraged the use of UF foam insulation and, thus, has a responsibility to assist ~hose borneo-mars who have suffered from using tHis tvpa of insulation. To a far greater extent and with disregard for the concern of triers being safety hazards associated with their product, the urea formaldehyde industry likewise promoted its use. The industry agrued against the existense of significant hazards until, in the face of overwhelming evidence that had existed for years, thoir product was banned. Thus, the urea formalde- hyde manufacturers and installers share significant responsi- bility for the damages suffered by homeowners who have installed UF foam. The owners of horses insulated with UF foam rightfully de- serve a means of undoing both the loss of property value and risk to their health that the insulation's presence presents. The most effective means is to remove the insulation. Accordingly, NHA urges this subcommittee to take action which would direct the foderal government and the responsible urea foreialdehyde foam manufacturers and installers to assume responsibility for the removal and replacement of urea formal- dehyde insulation in those cases where the affected homeowner or home purcnaser so requests. PAGENO="0456" 452 University of Waterloo V 4" "~`T:--c Waterloo, Ontario, Canada F c ItyofE o m t 1St des - Department of Man-Environment Studies * 519/885-1211 May 21, 1982 The Chairman Government Operations Committee Consumer Subcommittee House of Representatives WASHINGTON, D.C. Dear Sir: RE: Urea-formaldehyde foam insulation (UFFI) The newspapers have reported the testimony of Dr. Michael Newhouse before your committee. He testified that UFFI has no health effects. I trust you will also be hearing other views on UFFI. I don't know where Dr. Newhouse is getting his information. The fact is that many families have suffered severe health effects after their homes were insulated with UFFI. I know personally of several families which began to suffer these health effects long before there was any suspicion that the health effects were caused by UFFI. Therefore it is not possible that these families suffered health effects due to power of suggestion from stories in the media. It may well be that the health effects which have been observed are not due to formaldehyde. However this does not mean that there are no health effects. Twenty-five Years of Co-operative Education in Canada PAGENO="0457" 453 The health effects are a fact. We don't know for sure what is causing them. It may be chemicals other than formaldehyde in the UFFI formulation. It may be fine dust particles produced by the deterioration of UFFI. Dr. Albert Nantel of,~University) Quebec) has systematically studied thousands of cases. He has concluded that UFFI somehow suppresses the immune system of the human body. Therefore people very easily contract a variety of respiratory and other illnesses. I am enclosing a copy of an article from sources just as reputable as Dr. Newhouse. This article documents a case of severe allergic reaction caused by dust from UFFI. Yours sincerely ~ j Edward J. Parkas, Sc.D., P. Eng. Associate Professor EJF:pf Enc. PAGENO="0458" 454 S ltoscs:baem MIt, Chide PA, Italpets: Ml, .~ at. C.inssal efik-acy of aniia:bronc as an antiarrhyt!unc agent. Am Cardiol 1976,3P:933-44 3 Rowland K, Dawson H, Krikier DM. Amsodarurie in prophylanic of various suprave'ntricular arrbythmtas (ahstr). tie Ilcast J 1979; 41:372 4 Lul,be ~VF, McFadyen ML, Muller CA, Worlhtngtsn H, Opts LII. l'eoteclive action of arniodarone against yen- hicular fibrillation in the isolated perfused rat enact. Am J Catch-ti 1075; 43:533-40 5 Jeevell A, Lange-Nielsen F. Congenital deaf-motions, fancticcoal heart disease ssitls prolongation of the Q.T interval, and sudden death. Anc 1k-art J 1957; 54:09-63 C Cares LA, Vick RI.,, Okra JJ, MeNancara DC. Heritable Q-T prnlnngction without deafness. Circulation 1970; 41:39-43 7 Ma'J,ewu EC Jr Blount AW Jr Townsend JI. Q.T pro- loogsction and ventricular arrlsc;hntias, with and woicout deafness, in the sanse family; Am J Cardiol 1972; 29: 702-11 8 Schwartz PJ, Periti H, Malliar:i A. The long Q-T syn- dro,ne. Am Heart J 1915; 89:378-90 9 Segni El), Klein 110, David H, ls'aplinsky E. The man- agement of paeoxsmal ventricular tael:ycardia and hihril- latinn associated with the long Q.T syndrome (al:str). Am J Cardiol i9SO; 47:451 10 7.pes 131', Troop PJ. Nesv nnliarrhythmie agents: ami- - odarorie, aprindine, clisnpyramide, etluctozin, meoilcline, tocainide, verapamil. Am J Cardiol 1978; 41:1005-24 Asthma Induced by Dust From UreR-Formaldehyde Foam InsuIa~ing Mjterial* : Ecncgcla Feigas, M.D.; Warren V. Fiikxj, M.D.; and Cltctrics E. Th-0-d, M.D., F.C.C.?. A patient developed severe as1lc~na following insolation of her Louse with urca-fsrncaltlehydn foam. Jtroncisial challenge with the ttuo%Ont dust (`1 the fount cat,sctt an osthiuatk atlack; inhalation of formaldehyde, 3 ppm, did riot, Urca-fn'maldeltyde foam insulating ntatcrials (UF foam) are used extensively in the United States for wall cavity insulation in lto:nes, schools, hotels, anti hospitals and for frost protection as an overlay ott agri- cultural crops. The preparation antI chemistry of the 1fF foam basic been desctibed clscsvltere.~-° The industry claims that the UP fttttn is cnergy-savitog attd safe.3 Little is kits-nc ahs:ttt tlts: pres.cisttce of cliscaso' ittdttcrd by the tiff fstr.s. In vitro expcritnetcts that tested tite two ncajor ccsap,stctcta of lice UF foam, tlte "resin" ;tttd flu.' "I:sac~bsg solcatirni," love r,cisc-d the possibility that these u,spt:',yctrrizc'tl starling malerials may have title- tcritttis geccrlk atari eves czrs-ilsogcliie potettlitsl_~ Itt adchili;src, ii:loslation of f:otoc;ildehcydr ftcn:ro may cause ;tsthteta.~ Al 1's-Is those H p;cas. finanald:'hyds go-: ccl- 1.:-:::i .-.. .. .- a. :,s~ vases, Hoyt: (tour scat OIa)u i~cs:.d.:i:s:::, tl:sl,s:.te:. 1st-. Rcj'ila: acqec-sls. Scribe: cf Inbficct'io,se, Mayo Cl-sic, P.orhcairr, Mic;ss-tc:t:c .19101 tales the ic:s:c:o:s n,e:rtbra::cs, atsd ii: 11::: l7::;t 5-: icoclctstrial rcgccI:ctio::s specify that no co:ploycc be exposed to a conecntr;:tiosc of fortnale:-ly:le'gce~l,:; than 1 ppm for any 30-ttcinttte period of saophog.: CASE REPORT A 47-year-old svldte woman was evaluated at the slay5: Clinic for a 25-year history of perennial, severs: sterobi.rssj;. tant astlm:a. She had astbn:a as an infant until t:vo ra:~ age, but then sync symptonc-frce and in good health no:il Ia: 45th year when she again developed asthma in the fall 1077, She lad lived in the same farm house for thc previ- ous 28 years. tier symptoms began shortly nfiyr irnulolisa: of her home svith UF foam in the fall of 1177. In ApsO 1978, she developed, ss-jtlsost any apparent cause, a ens-crc ssthtna attack requiring emergency hsopilalicalieo. Sivcc March 1979, despite treatment ssttla glucorortiexidr, ho; asthma svorsened, and she was hospitalizerl eight time; prior to her visit to the Mayo clinic in December 1070. tIc; asthtc:a would worsen at night, especially upon nsval:enixz. She had never sn:oked nor laud actyoae else in her imr::edi;te funnily, Physical examination sn-as airremarkabls c:cept for some stigcctata from chronic glecacarticoid tlsnrar.y, the chest was clear to anscultation cod prresssiso. Ci.-~; x.ray film flnrtings were ss.bbin normal imihs, O0(~. It-SC ::taa~ daed labt:ratory tests were negative or cormal. Skis: cOo Is comcnon inbslants and molds, as sve0 an to sveed', grass-so. acid trees of the northnrn midsncst sn-ceo negative. Bronchial Prunocath's Tests All tests svere perfccrnccd or. different days oh-rug oh 8:00 AM. B~seIine fosv-volcne Loops sn-eec dc.te-rio:i:s:;st ea~t-: day prior to bronrhoprovoeaticn. AU .weornrcnrcni-s c-I 7.' basdir,a FE'c'1 snore 85 ~gccen-. cc geraic: ~f tin's prrO.vI'-C value. The first 40 csinoles of each bronchial st:;fes;;; ssc;y divided into four peeicds of ten minutes each. 15cr boosts- provocations sn-eve rxe;sctret- at the beginning of s-ret-s :5:5:1, and fow'volume loop noeas:crcmeots were clone at limo era of earl,. Subscq::cntly, additional Soss-s'otunse loops at 7 ansI 24 hours after inrccnehoprovocztian so-crc -scormiect to check for late reactions, oh drop in FEV, of 20 perrvnt or greater franc the baseline svas considered a positions test-. 0n day 1, we established the baseline flow-column loot-s. (in day 2, we perform-al brozch:is challenge salty the lschoissn descril:ed b> Pepyn and hlut:-l:ecoit5 usiog the dust of tl:e UF foam the patient had sought from love horns. Tire patient st-as cxton:rd to the ~jhairrlor, of rIco floe t:ooyaot dust for a total of tss'o nsincs:;.. An shasvn in Figure 1, fob- lons'hccg f:tur srctuentiiil rF.ailengen svith the UF Soon: rtusi, her FEW1 dropped in 50 ncinulrn to 64 percent and Sb hours later, to 51 perce::t of baseline. By 60 minutes, the pati:'nt developed srvere stcort::rss of breath, ss-iccrzr:g. xvi a dry cough. These symptoms ssece resersed promoptl~ by 0.3 ml of c~cincp1:ri:tu (1:1,000), subcutaneously. 7t-o l:e reaction uccurred. 0:: day 3, see perfarocti a c'outcai dOs- clcial chalhcc:ge using alumi:::::'.s aside dust (Fig 1) Ia cy- cluda Ihe pr.asilail:ty she nsigl:t be nu:saprciflastly rev!.--: to any kind of dast. No bronchial reaction oceorrcd. On cli-.' 4, nyc tested gase1s:o fcr:ssal;lcirt ale a r:o;,-otrat-::: a! rtcsc':t tox::c ni;. This ro:crnlr.Oirn of gascro:: hyde sn-as p:::c;e-d os nsn.'g:-rleci in rrferrncs ¶1. Tins' o'Otis'et 17 57- ,is5::'s a trIal :1 ci::ht sass-tan. 1'. 1'- . - On ctay 5, cs-c tcotzcc dad ::rs.,.t:::s.:i.I:'::, : -- from alocal dealer. No ueactioic ssas noted. `iso 1116 FRIGAS, FII.LEY, REED CHEST, 79: 6, JulIE: PAGENO="0459" ___ ____ 2 3 Time (hours) asthma living in homes insulated will, OF fo:rrrr, one asthmatic and two normal subjects not exposed to Ut! loam, were similarly tested by bronchial challenge to UF foam dust No rexalioo occurred. In all brm:choprxvoeatixn tests, the patient ar.d the controls were aware of tlxe nature of the challenge uxxterialu. lierause of the characteristic appear- ance of the dust, it was true possible to perform tire chat- leasge in a blind fashion. DiscussioN We fennel no reports suggesting a cause-and-effect relatirrxship betwrs.sa expusrare to Ill' toatn and asthma either axe aervo or eggro~uciort ri prc-todstit:g ast'asna. `rite case of our patirrrt suggests the latter. \Vc believe the reaction of our paticr:t to broneltoprovocattont svith lit! foam dust s/as specific for tins material because she did not react to alunxinunat oxide, an inert dust, and other patients wills astlrmo, including two who were exposed to UF insulation, did not react wiscra dial- lettged with this UF' foasas dust. i'ltc severity of tire response to the challenge greatly exceeded that oh- inined by srtggestions.'° It seems appropriate that in taking lie history of an asthmatic, a specific question altrauld be naked obcrut tIre nature of the Inane insttla- titan. We were imaformeti by NAIJFlfsl (National Asxo- `lotion of Urearfoanui Insulaliran Manufacturers-Fl:atence, Ky) tlsat emission of gaseous fornt:rldehyde may last for years frrllass'ing defective installment of an incor- rectly formulated UF foam; this has also beets reported by Bartmann." The air level of formalaieltydc in the indoor en'.'irrtrametat of Ilte patient's residence should be txtoasurrd and appropriate advice given. Urrfortnnatclv, the positive laronclrial cltallenge in our trlirmrt c~fcrs; liltIe itrforroalixra concerning which one ri lire marry components of tine OF foam caused tire fh~ final nasrlcrial is a crirnpkx o!~lrtnaa of cxrrr1rstntj~ some of which are rrrrktsoss'n.''5 It dares ap- p: sr jrsWcVCr, that the frrrro;rlrlr:l:ydr: was trot tire cause `:1 urrr patiettt's astitarri since brr:ncl:oprusocalixan with a, ... . `ar.,:., . ,,~, ~. .5:,. *:s7.aawl F'( ja.r;arttt to lay aw;ry (cur n Irrr treats', a r'r~s.xl;:,a;csl her frrrrr anraralits later. 11cr astl:nra wis ACKNOWLEDGMENTS: The authors wish to thank Jonas K:rlr,ax, MD, frorra tire Praimr:n:ary Fur,etioo Latrrrratcrry of usa Mayr Chine for expert arls'ice regardirrg tire preparation gaseous forrtrarldetxydrr nris.trrres in air, and Cheryl It. Aristialasors, technical editor, far iner crrmmetrts aad sugget- tirsns in tlae r'rs'iesv of this naanuseript. RF-FERENCES - I ttossiter WJ Jr, Matlrey fiG, Doargias ~`tB, Phrrce El'. Urea-fortnalrlehycie based foam Isntrlo'ls,rt: en swans- merat of tiscir properties and perlormance. US i)eat o~ Comntamercrr, National Bureau of Slarrriards Techanical Note 946, US Govemnanaerrt Printiog 019cc, Washingtrtn, 5977 2 Barsrraann H. rrepa:atiou and processing of urea-formal- dehyrie foam polymers: P,xrt 1. Aust Plastic and Pub, pp 13-17, October, 1976 .1 tiaumanrt II. Preparation and processing urea-formalde- hyde pulymers. Part If. Aust Plastic and Rob, pp 31-35, November, 1976 4 Morirs NC, Kubinstri II. Potential toraieity of materials used fee Irorne insulation. Tosicol Envirun Eafoty 5978~ 2:131-ti 5 T'ierrdrirk DJ, Lane DJ. Occupational formatin asthma. tic) frrrtust Men 1977; 31:11-18 Fsssct DW. Alrlehydes and acetols. In: Patty FA, ed industrial hygiene. anal trrxic,siogy. Ittd ed. Nov Yotk: Inlersrience, 1999-72:5963 7 National Institute of Ocrr:p;rtionsl Safety and Hygiene. Criteria frar a reconarnerrdcrt starratard: cccupationat ex- posure to formalrlelryde. Wasl;irrrgnn, US Urpt cf health, Education, anal Welfare, pir 95.10(1, 1973 8 t'epys J, Ita:tclrcr::ft 13). State of San art: bronchial t:crrvocalion tests hr rtie(:nie di.~ers':Es act analyrcs of asthma. Ann, 11ev fleniir firs thiS; 11:539.39 1) US l2~:t rat lIFtS', rat... fl, .`;",s~:', Ccstrr for l);;.'os.' Cs! ant, CO.rll. fle i,fiaZ, ti ,axs'iror:n:ent- its ,as';rtrrat ret `na1 `a,r.trst 1979; `1:17-iS 11 Sp:actr;m S. t.:ir:a:ai!s 13 Frnp'r'::y If, Snr:lnra:ia 3, Kiss'rrr:tri Itt ltespor"e rrl scthmal(cs ~, ,r.ratlrad:oiimo .11 llarr:rr,rr:r: I, l':ta,t.:.'a~ " :. `. a,.5t. r' ...` 5., 3 2 I 455 CHALLENGES t 0~,,, / A-'A Dust, Alumir.orn oxide *~C Dust, UF foam Epinephrine Ftcutrz 1. Bronchial reacthnr.s err ininala- i t ,, lion testing smith `alurninrarn oxide dust Ii'"" (triangles) and UF foam dust from pa. tient's hence (closed circlcs). FEy5 = forced expiratory volume at one second. 0 well cotatrohled with tlneophylhine at:d terbutaline with- out the need for glucocort!coids. GKST, 79; 6, JUNE, 1931 siJTlith\ llrt~Cr3'J Sf 0(51 i1c~t.tJS'1hS k~,STERU'J.. 71? PAGENO="0460" 456 Does your home qualify for an insulation grant? I ~ Government Gouvememsnt of Canada duCanada CanadlanHome Programmed'Iaofatlonthermlque Insulation Prmeam des résidencascanadennes HonourableAndréOuellet L'honorableAndrOuellat Mlnlstnc Utelatre PAGENO="0461" 457 Why do I need to improve my home's insulation anyway? Because its'costing you money if you don't and wasting the nation's precious fuel. You could be saving as much as one third your fuel bill every year with proper insulation: Fuel costs are rising every year, and at today's prices thatmeans an average saving of $180 a year for you. That's not peanuts. In fact, insulation is such a good deal it will pay for itself outright in less than five years. Afterthat it's like money in the bank And if our homes were pro- perly insulated, we Canadians could save ourselves the equivalent of one-and-a-half Syncrude-sized oil sands plants every year, or$1 billion in imported oil. More impor- tantly, every drop we save this year means we'll have it for next: What's the purpose of this program? The Canadian Home In- sulation Program is an idea developed by the Govem- ment of Canada to provide you, as a homeowner or tenant, with a financial in- centive to purchase insulating material so we can all save fuel and money. The program * will run for seven years be- ginning September 1,1977, and is scheduled to include all homes in Canada Is my house or apartment eligible? Yes, if it's: -a single home, semi- detached house or row housing unit -an apartment building of three storeys or less -a hostel unit owned and operated by a non-profit organization, govemment agency or post-secondary educational institution. And if it's: -your principal residence, occupied year round.Vacation homes are not eligible. And if: -it was built before 1921 in New Brunswiclç Quebec, Ontario, Manitoba and Saskatchewan, or before 1941 in Newfoundland, Alberta, B.C., the Yukon or Northwest Territories. Note: The Canadian Home Insulation Program is effective only inprovinces that have agreed to adopt certain measures to conserve energy. What if my house was built after that? Don't worry. Your home will probably become eligible eventually as the grant pro- gram expands over the next seven years to cover homes of most vintages. What kinds of insulating are covered? We'll help pay for insulating your attic, or walls, basement walls, or floors over unheated spaces. Sorry, but we can't cover the cost of caulking or weather- stripping around windows and doors, even though it's a very good (and inexpen- sive) thing for you to do. PAGENO="0462" (Vfhat kind of \ materials qualif~ They must be accepted by the Central Mortgage and Housing Corporation and have an acceptance number. Acceptable materials include: -Mineral wool (fiberglass, rock wool) -cellulosefibre -lightweight cellular plastic insulation(polyurethane, polystyrene) -expanded mica -urea formaldehyde Only up to 2/3 the cost of materials, (not labour), is covered by the program. Materials must have been bought after Septemberl, 1977, or the date your province joined the program, whichever is later. get the valuable 106 page step-by-step guide "Keeping the Heat In", free, from the Department of Energy, Mines and Resources. What's the aximum mount of the rant? u can obtain 2/3 of the tual cost of your materials a maximum of: 50 for detached, semi- tached or row housing nits; 200 for units in apartment uildings ofthree storeys or ess containing six units or less. $150 for units in apartment buildings of three storeys or less containing more than six units; $70 per bedroom for hostel units. Each unit is eligible foronly one grant underthis program. How do I apply for a grant? By filling out the Canadian Home Insulation Program grant application form, of course. The form is easy to understand and comes with its own "How to Apply" guide. Isthe grant taxable? Yes~yZ)u'lI receive a tax slip in titlE to include it on your tax r~um. 458 Naturally, be sure you fill it out accurately and completely. Send~ the application accon~panied by the original bills ~ invoice for materals. If you irave any part of the workdone by a contractor, havehim show clearly on the involee the breakdown between materials and labour as orgy materials are included underthe grant. .Whatifl' t very-~öâd with Installing insulation is easier than you thihk For some jobs you don't even need to know how to use a hammer. Your local insUlation dealer or hardware supplier can provide a wealth of helpful * advice on the best CMHC accepted materials and how to install them. You can also For more information Ora grant application form, writeor phone: Canalian Home Insulation Pro~am P.O. Box 700 St. Laurent, Quebec H4L5A8 Call collect: (514) 341-1511 08:30 to 16:30 hours (your local time) Aussidisponible en français. Téféplione:(514) 341-1511 4 frasi virés~ PAGENO="0463" 459 U) E o 0 000000 00000 Z00000 00000 -.00000 0000 - -0 ~ ~z C I- ~ o owwiuww wwwww I- 00000 :~0O00O ~-0zzzzz zz~zzz - WDD~D DDD~ U) I- z K) ~ D ~ 0000 I-. 0~ 0000 U) < 0000 .- _l .z*~~mø. 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