First Name | Hal |
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Last Name | Levin |
Email Address | hal.levin@buildingecology.com |
Affiliation | Building Ecology Research Group |
Subject | CompWood reg |
Comment | 1. The target levels of formaldehyde emissions for this regulation are far too high. It makes very little sense to implement this regulatory process without achieving a far more substantial difference in the ultimate exposures of the population. Formaldehyde is a carcinogen and irritant and a more vigorous effort to control population exposure from CWP is warranted. Substantial reductions in formaldehyde emissions from CWPs have been achieved over the past 25 years through more careful formulation of adhesives and through improved quality control in the CWP manufacturing process. Further reduction is technically feasible and should not be dismissed as the preferable option. 2. Alternative (non-formaldehyde based) adhesives are also available for the proposed regulated products in which formaldehyde is widely used. It is difficult to justify continued population exposure to formaldehyde at the levels contemplated in the proposed regulated in light of this fact and the carcinogen status of formaldehyde. 3. State office buildings (Capitol Area East End Project) have been built during the past five years where far lower criteria were used for formaldehyde emissions. Proportional reductions of more than a factor of three would be appropriate based on the standards used for the State's own office buildings. 4. The economic analysis is flawed in that it does not take into account the cost of ventilation necessary to reduce airborne concentrations of formaldehyde by dilution ventilation to achieve levels that could be achieved more effectively at the one-time first cost of lower emitting CWP. This ventilation has an impact not only on operating costs but also on carbon emissions due to electric power plant operation and emissions. For example, if emissions were reduced by a factor of four, roughly only one-fourth the outdoor air would be necessary to dilute the concentrations in the air according to an oversimplified mass balance model to achieve the same indoor air concentration. Since the emissions from CWP generally have half-lives of several years, this means that several years worth of significantly increased ventilation would be necessary to provide the same protection to the public as would be provided by a reduction in the intial source strength of formaldehyde emissions. 5. CWPs are one of if not the dominant sources of formaldehyde emissions to the indoor environment, especially but not exclusively in residential environments. Outdoor air ventilation is not generally common or adequate there, mostly provided by incidental leakage of the building exterior "envelope." While energy cost and carbon emission limitations are important current and future constraints on energy consumption to ventilate and to heat and cool outdoor air used for ventilation, the incentives for source strength reduction are likely to increase considerably in the coming years in order to achieve a given level of general population exposure to indoor source pollutants. 6. CARB has had a relatively forward-looking guideline and target for indoor formaldehyde concentrations for many years now. This proposed regulation is far less stringent that what would be necessary to achieve that target. CARB should take more effective action now on this well-known and widely-distributed substance to reduce the future costs of reduction by ventilation or removal and replacement of strong sources, especially the widely-used CWP. |
Attachment | www.arb.ca.gov/lists/compwood07/2-comment_by_hal_levin_on_carb_proposed_regulation_of_cwp.doc |
Original File Name | Comment by Hal Levin on CARB proposed regulation of CWP.doc |
Date and Time Comment Was Submitted | 2007-03-28 16:51:36 |
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