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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
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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)
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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)
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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
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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)
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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
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.]
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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
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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.
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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
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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.
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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.
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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.
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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.
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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
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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
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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)
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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)
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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)
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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
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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
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-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.
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-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
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-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.
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-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
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-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"
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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. -
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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.
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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.
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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
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WIND
WIND
WIND
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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.
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- 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
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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
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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.
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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
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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.
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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
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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.
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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.
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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.
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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.
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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.
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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.
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- 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
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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.
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- 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
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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.
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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.
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- 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
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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.
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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"
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- 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"
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- 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
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- 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.
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-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.
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- 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.
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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
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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
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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"
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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"
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- 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~'~"
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- 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"
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-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"
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- 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.
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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.
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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.
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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"
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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"
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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.
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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"
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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"
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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"
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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:]
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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"
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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"
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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"
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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"
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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"
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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
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PAGENO="0286"
282
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PAGENO="0287"
283
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PAGENO="0288"
284
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PAGENO="0289"
285
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PAGENO="0290"
286
LULUbM~ ~1~UU~ ~U'~
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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
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IL PthN51~1L1T'( 1ff 1~TER4[fl~ W~
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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
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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
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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.
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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.
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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.
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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
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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.
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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
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