Friday, June 10, 2011
The New York Times noted this week that the National Toxicology Program has released its Report on Carcinogens -- Twelfth Edition. One of the newly listed chemicals "known to be a human carcinogen" is formaldehyde, which is most commonly used "in the production of industrial resins," according to the report. These resins are used as "binders for composite wood products," among other things. The EPA describes the presence of formaldehyde in our homes in somewhat simpler terms: "Pressed wood products made for indoor use include: particleboard (used as sub-flooring and shelving and in cabinetry and furniture); hardwood plywood paneling (used for decorative wall covering and used in cabinets and furniture); and medium density fiberboard (used for drawer fronts, cabinets, and furniture tops)."
I have never found the time in my Environmental Law class to address indoor air quality issues, but reports like this remind me that I probably should. Congress added "Formaldehyde Standards for Composite Wood Products" to the Toxic Substances Control Act last year, which, among other things, provides a formal definition for "ultra low-emitting formaldehyde resin"--the stuff we're supposed to look for in products if we want to reduce indoor formaldehyde levels. But students probably need more than TSCA when it comes to discussing indoor air quality. The issue also seems to call for discussion of the rise of voluntary standards, such as LEED's focus on low-emission materials. Addressing indoor air quality issues might also allow synthesis of several statutes introduced earlier in the class, such as the Clean Air Act, TSCA, and OSHA, and might be closer to home for many students. After all, many of our students may sit in particleboard chairs at desks covered with medium density fiberboard.