The Environmental Protection Agency (EPA) has made available and are now soliciting public comment on the 2024 draft risk evaluation for formaldehyde prepared under the Toxic Substances Control Act (TSCA). An unreasonable risk determination is likely to result in a formaldehyde ban or unachievable workplace health standards. As an initial step, EPA is holding a virtual preparatory public meeting on May 7, 2024, for the Science Advisory Committee on Chemicals to consider the scope and clarity of the draft charge questions for their review.

Register here before noon on May 3 and join May 7^th public meeting which is virtual and provide oral comments.

NAA members are encouraged to provide the following oral comments to the SACC. 

• Briefly discuss your farm, laboratory or business and the use of formaldehyde, including identifying key conditions of use and your reliance on availability of formaldehyde as a fish health therapeutant or tissue fixative.
• Describe economic and societal benefits of your farm, laboratory or business and the use of formaldehyde in the context of these key TSCA provisions.
• EPA must “consider… whether technically and economically feasible alternatives that benefit health or the environment, compared to the use so proposed to be prohibited or restricted, will be reasonably available as a substitute…” (Section 6(c)(2) of TSCA).
• Section 6(g) provides for limited exemptions for uses in which: Compliance would “significantly disrupt the national economy, national security, or critical infrastructure”; “critical or essential use for which no technically and economically feasible safer alternative is available”; The use “provides a substantial benefit to health, the environment, or public safety.”
• Thank the peer reviewers for serving on the Science Advisory Committee on Chemicals and emphasize their important role in ensuring the high quality of EPA science and the particular importance here due to the economic and social impacts that would come from inappropriate restrictions on formaldehyde use.