First Name | Tom |
---|---|
Last Name | Cooper |
Email Address | thomas.cooper@kp.org |
Affiliation | Kaiser Permanente |
Subject | Kaiser Permanente's Position on ATCM |
Comment | On behalf of Kaiser Permanente I would like to thank the California Air Resources Board (CARB) for their excellent work in researching the issues associated with formaldehyde exposure and risk. As one of the largest employers in California and with more 6.3 million members of our health plan, Kaiser Permanente is extremely concerned with the health impact of toxic materials to our staff, patients, and the communities we serve. We commend the CARB for raising the dangers of formaldehyde exposure to the light of public discourse. Because composite wood products are made using large amounts of urea formaldehyde resins as a binder, these products create formaldehyde emissions that are toxic. The CARB estimated that as much as 800 tons of formaldehyde were emitted in California from composite wood products in 2002 (based on products consumed between 1983 and 2002) leading to hazardous concentration levels in the air in buildings, including the hundreds of clinics, hospitals, and other buildings in California owned by Kaiser Permanente. California has recognized that there is no known safe level of formaldehyde, as the Office of Environmental Health Hazards Assessment (OEHHA) determined that the safe reference exposure level (CREL) for formaldehyde was lower than the level of formaldehyde already in the ambient air. Less than three years ago, in 2004, the World Health Organization’s International Agency for Research on Cancer (IARC) updated its report on formaldehyde. Based on new information from studies of persons exposed to formaldehyde, IARC changed its position that formaldehyde was a "probable carcinogen" to conclude that formaldehyde is "carcinogenic to humans". And as we all know cancer is one of the leading causes of illness and deaths in California and in the nation. In addition to IARC, other national and international regulatory agencies have determined that formaldehyde is a public health and occupational concern. The list includes The National Toxicology Program (NTP), The National Institute for Occupational Safety and Health (NIOSH) ,and The Association of Occupational and Environmental Clinics (AOEC). The EPA Integrated Risk Information System (IRIS) found that formaldehyde is a probable human carcinogen in animal studies. Moreover, the EPA under the Clean Air Act, has concluded that formaldehyde is a hazardous air pollutant. Kaiser Permanente has long understood the connection between environmental hazards and health outcomes. We have been very active in our attempts to remove toxic materials from our facilities that pose a risk to our staff and patients. We have been diligent in our efforts to evaluate the products we purchase and materials we use for their impact on workplace, patient, and environmental safety. The result of this effort is that all our facilities are virtually mercury free and we have removed other persistent bioaccumulative toxins such as DEHP and polyvinyl chloride from most of the products we purchase. Where less toxic alternatives have not existed we have pushed the market place to develop safer products. Based on the plethora of information raising concerns about formaldehyde exposure in occupational settings, in buildings, and in ambient air, Kaiser Permanente has taken the position that it is one of our chemicals of concern. This has meant that Kaiser Permanente has researched alternative products that do not contain formaldehyde. Our overall goal has been to replace products that pose a danger to our staff, patients and the public with safer materials without added cost. We have an active campaign to reduce formaldehyde in the furniture, fabric, casework, and building insulation we use in our facilities. However, the cost of many of the alternatives are significantly higher than those products containing formaldehyde. We find this primarily due to these alternatives not having a significant enough market share to be cost competitive with those products that pose a health risk. If we look at the larger picture and include the health care cost to the State as a whole in treating cancer patients and others whose condition may be impacted by their exposure to formaldehyde, then the cost of inaction is far greater to all of us. We urge CARB to adopt stricter guidelines for formaldehyde levels as this set the climate for manufacturers to develop formaldehyde-free alternatives that will be competitive in the marketplace. As a large purchaser in California we can't make this market change to safer materials without your support. For the sake of the health of all of us we strongly support CARB's efforts to protect Californians from this known carcinogen. Thank you, Tom Cooper Kaiser Permanente Chairperson, High Performance Buildings Committee |
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Date and Time Comment Was Submitted | 2007-04-20 10:34:41 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.