--
                                     0.08
                                       --
                                       --
                                       --
                    Phase 2 Formaldehyde Emission Standards
                                Effective Date
                                  HWPW-VC [b]
                                  HWPW-CC [c]
                                      PB
                                      MDF
                                   tMDF [d]
                                   Jan 2011
                                     0.05
                                       --
                                     0.09
                                     0.11
                                       --
                                   Jan 2012
                                       --
                                       --
                                       --
                                       --
                                     0.13
                                   July 2012
                                       --
                                     0.05
                                       --
                                       --
                                       --
a  -  ppm = parts per million.  In this case, parts of formaldehyde per million parts of air.
b  -  HWPW-VC = hardwood plywood  -  veneer core.
c  -  HWPW-CC = hardwood plywood  -  composite core.
d  -  tMDF = thin medium-density fiberboard (8-mm or thinner).
Source: CARB 2007a

Table C-3.  Formaldehyde Emission Limits and Corresponding Emission Rates as Measured using ASTM E1333 under HUD, CARB, and FSCWPA

           HUD, CARB, and FSCWPA Limits as Measured from ASTM E1333
                          ASTM E1333 Test Parameters
                      Calculated Values (see Appendix E)

                              Concentration (ppm)
                            Concentration (mg/m[3])
                           Loading Ratio (m[2]/m[3])
                           Air Change Rate (hr[-1])
                    Formaldehyde Emission Rate (mg/m[2]-hr)
                   Area-Specific Airflow Rate (m[3]/m[2]-hr)
                                     HWPW
HUD
                                      0.2
                                     0.246
                                     0.43
                                      0.5
                                    0.2858
                                     1.16
CARB Phase 1
                                     0.08
                                     0.098
                                     0.43
                                      0.5
                                    0.1143
                                     1.16
FSCWPA / CARB Phase 2
                                     0.05
                                     0.061
                                     0.43
                                      0.5
                                    0.0715
                                     1.16
ULEF
                                     0.045
                                    0.0553
                                     0.43
                                      0.5
                                    0.0643
                                     1.16
NAF
                                     0.04
                                    0.0492
                                     0.43
                                      0.5
                                    0.0572
                                     1.16
                                      PB
HUD
                                      0.3
                                     0.369
                                     0.43
                                      0.5
                                    0.4287
                                     1.16
CARB Phase 1
                                     0.18
                                     0.221
                                     0.43
                                      0.5
                                    0.2572
                                     1.16
FSCWPA / CARB Phase 2
                                     0.09
                                     0.111
                                     0.43
                                      0.5
                                    0.1286
                                     1.16
ULEF
                                     0.045
                                     0.055
                                     0.43
                                      0.5
                                    0.0643
                                     1.16
NAF
                                     0.04
                                     0.049
                                     0.43
                                      0.5
                                    0.0572
                                     1.16
                                      MDF
HUD
                                     None
                                      --
                                      --
                                      --
                                      --
                                      --
CARB Phase 1
                                     0.21
                                     0.258
                                     0.26
                                      0.5
                                    0.4963
                                     1.92
FSCWPA / CARB Phase 2
                                     0.11
                                     0.135
                                     0.26
                                      0.5
                                    0.2600
                                     1.92
ULEF
                                     0.05
                                     0.061
                                     0.26
                                      0.5
                                    0.1182
                                     1.92
NAF
                                     0.04
                                     0.049
                                     0.26
                                      0.5
                                    0.0945
                                     1.92

Appendix D
FORMALDEHYDE CWP OFF-GASSING EMISSION LEVEL DATA FOR THE PRE-BASELINE PERIOD, BASELINE, AND THE ANALYTICAL OPTIONS

Use of Emission Levels in the Assessment of Formaldehyde Occupational Exposure

Emission levels for formaldehyde off-gassing from CWP, which have units of concentration, are converted to emission rates, which have units of flux, and are used in the mass balance equations used to calculate indoor air concentrations due to off-gassing of CWPs in fabrication sites and in office buildings for the baseline and the three analytical options.  Pre-baseline emission levels are used to calculate pre-baseline indoor air concentrations in CWP fabrication sites for the purpose of comparing model results to pre-baseline OSHA IMIS data as described in Section <IP_ADDRESS>.  Pre-baseline emission levels are also used to estimate the barrier effectiveness of the finishing (coating, overlays, etc) of the CWP from which office building workstation components are fabricated.  This barrier effectiveness is used in the calculation of formaldehyde indoor air concentration in office buildings for the baseline and the three analytical options (see Section <IP_ADDRESS> and Appendix E).
Emission Levels of Pre-Baseline CWPs

This section discusses the available pre-baseline emission level data and the estimation of pre-baseline emission levels.  The pre-baseline emission levels used in this assessment are summarized in Table D-1 below.  The data used to estimate these emission levels are presented in Table D-2.
Considerable information is available on the emission levels of domestically-produced pre-baseline products as shown in Table D-2.  As seen in this table, at the beginning of the pre-baseline period of 2002 to 2009, the production-weighted average emission levels of domestically-produced CWP were close to the CARB ATCM Phase 1 limits while the range of emission levels for these products had a lower bound that was less than the CARB ATCM Phase 1 standard emission level, and an upper bound that was considerably greater.  In ANPR submissions, it is noted that 75% of HWPW and 96% of PB and MDF met the CARB ATCM Phase 1 limit by 2009.  Therefore, the CARB ATCM Phase 1 limits were assumed to be representative of average pre-baseline emission levels for CWP produced domestically during the pre-baseline period of 2002 to 2009, and the average emission levels for domestically-produced HWPW, PB, and MDF were equated to the CARB ATCM Phase 1 limits (0.08 ppm, 0.18 ppm, and 0.21 ppm, respectively).
Emission levels of imported pre-baseline CWPs are not available and were estimated taking into account temporal trends in the emission levels of domestically-produced CWP and the reported emission levels of imported CWP.  The emission levels of baseline products (domestically produced and imported) and their share of U.S. consumption is provided in the market profile (USEPA 2010a) in Table 12-5.  A comparison of Table D-2 and Table 12-5 in the market profile (reproduced as Table D-3 in this appendix) shows that a considerable decrease in the emission levels of domestically-produced CWP will occur in going from the pre-baseline period to the baseline.  This temporal trend was assumed to apply to imported CWP such that there would be a decline in the emission levels of imported CWP from the pre-baseline period to the baseline.  The pre-baseline emission levels for Canadian imported CWP and non-Canadian imported CWP were estimated differently as discussed below.
According to Table 12-5 in the market profile (USEPA 2010a), baseline CWP imported from Canada have emission levels that are identical to the emission levels of domestically-produced baseline CWP.  This similarity was assumed to extend to the pre-baseline period, and therefore CWP imported from Canada during the pre-baseline period were assumed to have emission levels that are identical to the values assumed for domestically produced pre-baseline CWP.
Most of the non-Canadian imported CWP will adhere to the CARB Phase 2, ULEF, or NAF standards at baseline, but will have emission level values that are different from those of U.S. and Canadian CWP.  The baseline emission levels of non-Canadian imports are likely not representative of pre-baseline emission levels of these imports assuming that there will be a decline in emission levels of imported CWP from the pre-baseline to baseline as discussed above.  The fraction of imported baseline CWP that will not adhere to any of the CARB emission standards will be approximately 26%, 37%, and 10% for HWPW, PB, and MDF, respectively.  The average values of the emission levels for these volumes will be 0.163 ppm, 0.384 ppm, and 0.502 ppm for HWPW, PB, and MDF, respectively, as shown in Table D-2.  It is assumed that these emission levels are representative of the average pre-baseline emission levels for each CWP type for imported CWP.
In conclusion, the average emission levels for domestic and Canadian pre-baseline HWPW, PB, and MDF are assumed to be equal to the CARB ATCM Phase 1 limits (0.08 ppm, 0.18 ppm, and 0.21 ppm, respectively).  The average emission levels for imported pre-baseline HWPW, PB, and MDF are assumed to be equal to 0.163 ppm, 0.384 ppm, and 0.502 ppm, respectively.
An average emission level for all three CWP was used in the estimation of barrier effectiveness for use in the calculation of office building indoor air concentration.  Therefore, these emission levels are averaged together.  First, a volume-weighted average of the emission levels of domestically-produced and imported CWP is calculated for each individual CWP type.  The EPA market profile provides the 2005 volume-based shares of domestic consumption of domestic/Canadian and imported CWP (Table 12-4 in USEPA 2010a).  The volume-based shares of domestic consumption of non-Canadian imported CWPs are 64%, 3.5%, and 7.6% for HWPW, PB, and MDF, respectively.  The shares of domestic/Canadian CWPs are the difference between 100% and the import shares.  A volume-weighted average emission level is calculated for each CWP type as follows.  The emission rates (in units of flux) are similarly calculated.
For HWPW:
0.64x0.163 ppm+0.36x0.08 ppm=0.13 ppm

For PB:
0.035x0.384 ppm+0.965x0.18 ppm=0.19 ppm

For MDF:
0.076x0.502 ppm+0.924x0.21 ppm=0.23 ppm

Next, a single volume-weighted average emission level for all three CWP types is calculated from the three CWP weighted averages calculated above.  Table 12-4 in the EPA market profile (USEPA 2010a) also provides annual consumption volumes of the three CWP for the year 2005.  Based on these data, the consumption volumes of HWPW, PB, and MDF as a fraction of total the total consumption volume for these three CWP was 31.1%, 46.4%, and 22.5%, respectively.  The single volume-weighted average emission level for all three CWPs is calculated as follows.  The emission rates (in units of flux) are similarly calculated.
0.311x0.13 ppm+0.464x0.19 ppm+0.225x0.23 ppm=0.18 ppm

Table D-1. Pre-Baseline Formaldehyde Emission Levels for CWPs used in this Assessment
                                   CWP Type
                              Domestic or Import
                                     Units
                                 Average Value
                            Volume-Weighted Average
                                     Basis
HWPW
Domestics
ppm
                                     0.08
                                     0.13
CARB ATCM Phase 1 Limit

Imports
ppm
                                     0.163

Baseline imports that do not meet any emission standard
PB
Domestics
ppm
                                     0.18
                                     0.19
CARB ATCM Phase 1 Limit

Imports
ppm
                                     0.384

Baseline imports that do not meet any emission standard
MDF
Domestics
ppm
                                     0.21
                                     0.23
CARB ATCM Phase 1 Limit

Imports
ppm
                                     0.502

Baseline imports that do not meet any emission standard
Volume-Weighted Average of the Volume-Weighted Averages for the Three CWPs (ppm)
                                     0.18

HWPW
Domestics
ug/m[2]-h
                                     114.3
                                     190.3
Calculated from emission level based on ASTM E1333 (see Appendix E)

Imports
ug/m[2]-h
                                     232.9

PB
Domestics
ug/m[2]-h
                                     257.2
                                     267.3

Imports
ug/m[2]-h
                                     548.8

MDF
Domestics
ug/m[2]-h
                                     496.3
                                     548.9

Imports
ug/m[2]-h
                                    1,186.5

Volume-Weighted Average of the Volume-Weighted Averages for the Three CWPs (ug/m[2]-h)
                                     306.7

Table D-2.  Data Used to Determine Pre-Baseline Emission Levels for Composite Wood Products
                                    Timeline
                               Information Source
                                    HWPW [a]
                                     PB [b]
                                     MDF [b]
                                 Domestic CWPs
2002
CARB survey
                          Production-Weighted Average

                                   0.09 ppm
                                   0.18 ppm
                                   0.25 ppm

                  % of U.S. Production Represented in Survey

                                      73%
                                      53%
                                      83%

                           Range in Survey Responses

                               0.07 to 0.75 ppm
                               0.13 to 0.24 ppm
                               0.03 to 0.31 ppm
End of 2008 / Beginning of 2009
ANPR Submissions
75% of domestically-produced CWP were CARB Phase 1 compliant
96% of domestically-produced CWP were CARB P1 compliant
96% of domestically-produced CWP were CARB P1 compliant
Later in 2009
ANPR Submissions
90% of domestics expected to be CARB P1 compliant
                                      --
                                      --
Average Emission Levels for Imported Baseline CWPs That Do Not Meet Any of the CARB Emission Standards (USEPA 2010a) [c]
                                   Baseline
EPA market profile
                                   0.163 ppm
                                   0.384 ppm
                                   0.502 ppm
 a  -  A submission from HPVA in May 2008 estimated that domestically-produced HWPW will be in compliance with CARB Phase 1. Phase 2 limits require new technologies, which have not been in commercial use and some only recently invented and patented. Additionally, a submission from HPVA in February 2009 estimated that 75% of North American HWPW was CARB certified and soon 90% or more will be CARB certified. "CARB certified" is assumed to mean CARB Phase 1 per the statements made in the May 2008 submission. The term "soon" is uncertain; therefore, the point in time in which 90% of domestics were expected to meet CARB Phase 1 is uncertain.
 b  -  A submission from CPA in May 2008 stated that "almost all" domestic production is expected to be compliant with CARB Phase 1 and 2. The volume related to "almost all" is uncertain. This submission also states that "eventually" this rate of compliance would be reached; the time frame associated with "eventually" is uncertain. CPA did estimate that 96% of domestics were Phase 1 compliant by the end of 2008.
 c  -  Average emission levels of imported CWPs at baseline that do not meet any of the CARB emission standards are used as estimates of the average emission levels of all imported CWPs during pre-baseline.

Emission Levels of Baseline CWP and CWP that Would be Produced Under the Analytical Options

The EPA market profile provides emission levels for CWPs at baseline.  These emission levels and their corresponding volume-based shares of U.S. consumption are summarized in Table D-3 below.  Emission levels and their corresponding volume-based shares of U.S. consumption for the analytical options were determined based on the baseline values and are given in Table D-4 through Table D-6 (USEPA 2009b).
Table D-3.  Baseline Emission Levels and Corresponding U.S. Consumption (Copy of Table 12-5 in Market Profile)
                               Emission Standard
                               Hardwood Plywood
                                      MDF
                                 Particleboard

                                   U.S./Can.
                                 Non-U.S./Can.
                                   U.S./Can.
                                 Non-U.S./Can.
                                   U.S./Can.
                                 Non-U.S./Can.
                            Average Emissions (ppm)
None
                                     0.058
                                     0.163
                                       -
                                     0.502
                                     0.058
                                     0.384
CARB P1
                                       -
                                       -
                                       -
                                       -
                                     0.090
                                       -
CARB P2
                                     0.032
                                     0.015
                                     0.082
                                     0.047
                                     0.057
                                     0.036
ULEF
                                       -
                                       -
                                     0.024
                                       -
                                     0.042
                                       -
NAF
                                     0.013
                                       -
                                     0.035
                                       -
                                     0.013
                                       -
                           Share of U.S. Consumption
None
                                     0.1%
                                     16.6%
                                       -
                                     0.8%
                                     0.2%
                                     1.1%
CARB P1
                                       -
                                       -
                                       -
                                       -
                                     1.7%
                                       -
CARB P2
                                     19.7%
                                     47.4%
                                     79.2%
                                     7.2%
                                     85.0%
                                     1.9%
ULEF
                                       -
                                       -
                                     4.2%
                                       -
                                     3.0%
                                       -
NAF
                                     16.2%
                                       -
                                     8.6%
                                       -
                                     7.1%
                                       -
                    Weighted Average Emission Levels (ppm)
National Average
                                     0.043
                                     0.076
                                     0.057

Table D-4.  Emission Levels and Corresponding U.S. Share of Consumption for Analytical Option 1 (CARB Phase 1)
                               Emission Standard
                               Hardwood Plywood
                                      MDF
                                 Particleboard

                                   U.S./Can.
                                 Non-U.S./Can.
                                   U.S./Can.
                                 Non-U.S./Can.
                                   U.S./Can.
                                 Non-U.S./Can.
                            Average Emissions (ppm)
None
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -
CARB P1 (previously NOT CARB P1)
                                   0.058 [a]
                                     0.058
                                       -
                                   0.14 [b]
                                   0.058 [a]
                                     0.090
Already at CARB P1
                                       -
                                       -
                                       -
                                       -
                                     0.090
                                       -
CARB P2
                                     0.032
                                     0.015
                                     0.082
                                     0.047
                                     0.057
                                     0.036
ULEF
                                       -
                                       -
                                     0.024
                                       -
                                     0.042
                                       -
NAF
                                     0.013
                                       -
                                     0.035
                                       -
                                     0.013
                                       -
                           Share of U.S. Consumption
None
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -
CARB P1 (previously NOT CARB P1)
                                     0.1%
                                     16.6%
                                       -
                                     0.8%
                                     0.2%
                                     1.1%
Already at CARB P1
                                       -
                                       -
                                       -
                                       -
                                     1.7%
                                       -
CARB P2
                                     19.7%
                                     47.4%
                                     79.2%
                                     7.2%
                                     85.0%
                                     1.9%
ULEF
                                       -
                                       -
                                     4.2%
                                       -
                                     3.0%
                                       -
NAF
                                     16.2%
                                       -
                                     8.6%
                                       -
                                     7.1%
                                       -
                    Weighted Average Emission Levels (ppm)
National Average
                                     0.025
                                     0.073
                                     0.054
Source: USEPA 2009b
a  -  This share of consumption was previously given for products not meeting any standard at baseline, but the baseline emission level complies with CARB Phase 1 and thus does not change.
b  -  This emission level is 67% of the CARB Phase 1 limit.

Table D-5.  Emission Levels and Corresponding U.S. Share of Consumption for Analytical Option 2 (FSCWPA/CARB Phase 2)
                               Emission Standard
                               Hardwood Plywood
                                      MDF
                                 Particleboard

                                   U.S./Can.
                                 Non-U.S./Can.
                                   U.S./Can.
                                 Non-U.S./Can.
                                   U.S./Can.
                                 Non-U.S./Can.
                            Average Emissions (ppm)
None
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -
CARB P1
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -
CARB P2 (previously not CARB P2)
                                     0.032
                                     0.032
                                       -
                                     0.082
                                     0.057
                                     0.057
Already at CARB P2
                                     0.032
                                     0.015
                                     0.082
                                     0.047
                                     0.057
                                     0.036
ULEF
                                       -
                                       -
                                     0.024
                                       -
                                     0.042
                                       -
NAF
                                     0.013
                                       -
                                     0.035
                                       -
                                     0.013
                                       -
                           Share of U.S. Consumption
None
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -
CARB P1
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -
CARB P2 (previously not CARB P2)
                                     0.1%
                                     16.6%
                                       -
                                     0.8%
                                     1.9%
                                     1.1%
Already at CARB P2
                                     19.7%
                                     47.4%
                                     79.2%
                                     7.2%
                                     85.0%
                                     1.9%
ULEF
                                       -
                                       -
                                     4.2%
                                       -
                                     3.0%
                                       -
NAF
                                     16.2%
                                       -
                                     8.6%
                                       -
                                     7.1%
                                       -
                    Weighted Average Emission Levels (ppm)
National Average
                                     0.021
                                     0.073
                                     0.053
Source: USEPA 2009b

Table D-6.  Emission Levels and Corresponding U.S. Share of Consumption for Analytical Option 3 (NAF)
                               Emission Standard
                               Hardwood Plywood
                                      MDF
                                 Particleboard

                                   U.S./Can.
                                 Non-U.S./Can.
                                   U.S./Can.
                                 Non-U.S./Can.
                                   U.S./Can.
                                 Non-U.S./Can.
                            Average Emissions (ppm)
None
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -
CARB P1
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -
CARB P2
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -
NAF (previously not NAF with non-NAF emissions)[a]
                                     0.013
                                     0.013
                                     0.035
                                     0.035
                                     0.013
                                     0.013
NAF (previously not NAF with NAF emissions)[b]

                                     0.024
                                       -
                                       -

Already at NAF
                                     0.013
                                       -
                                     0.035
                                       -
                                     0.013
                                       -
                           Share of U.S. Consumption
None
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -
CARB P1
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -
CARB P2
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -
NAF (previously not NAF with non-NAF emissions)[a]
                                     19.8%
                                     64.0%
                                     79.2%
                                     8.0%
                                     89.9%
                                      3%
NAF (previously not NAF with NAF emissions)[b]

                                     4.2%
                                       -
                                       -

Already at NAF
                                     16.2%
                                       -
                                     8.6%
                                       -
                                     7.1%
                                       -
                    Weighted Average Emission Levels (ppm)
National Average
                                     0.013
                                     0.035
                                     0.013
Source: USEPA 2009b
a  -  These shares of consumption were previously given for products not meeting the NAF standard at baseline, and the emission levels were changed to match the domestic baseline NAF emission levels.
b - These shares of consumption were previously given for products not meeting the NAF standard at baseline, but the baseline emission level complies with NAF and thus does not change.

Appendix E
MODELING METHODOLOGY FOR ESTIMATING INDOOR AIR CONCENTRATIONS RELATED TO BASELINE AND ANALYTICAL OPTIONS

1.0	Indoor Air Concentration Assessment Methods

This section of this appendix describes the modeling methodology for estimating indoor air concentrations related to baseline and analytical option periods for the three composite wood products of interest: HWPW, PB, and MDF.  Both inhalation and dermal exposures are assessed.
1.1	CWP Fabrication Indoor Air Concentration Assessment Method

An airborne concentration of a chemical contaminant in a control volume may be determined from a mass balance on the chemical as presented in Equation 1 (USEPA 1991a).
					C=SQ						Eqn (1)

where:
      C	=	Airborne concentration of the chemical in the work space (ug/m[3]);
      S	=	Generation rate of the chemical as a vapor or gas from the source of interest in the work space (ug/h); and
      Q	=	Volumetric ventilation rate of the work space (m[3]/h).

The following assumptions apply to this model:
Extinction of the chemical (adsorption, absorption, or chemical transformation) resulting from deposition on walls and equipment, condensation of hot vapors, and photodegradation of chemicals is negligible;
The incoming air is contaminant-free;
The concentration of contaminant at initial time is negligible (there is no background concentration or other generation sources of the contaminant);
The generation and ventilation rates are constant over time (steady-state assumption); and
Room air and ventilation air mix ideally.

Equation 1 is modified to account for the presence of contaminant in the incoming (outdoor) air.  A new mass balance is derived to arrive at Equation 2.
					C=SQ+Coind				Eqn (2)

where:
      Co[ind]	=	Concentration of contaminant in the outdoor air (ug/m[3]).

To account for non-ideal mixing of the ventilation air and the contaminated room air, a dimensionless mixing factor, k, is used.  One interpretation of the mixing factor is a representation of the fraction, k, of the ventilation air that completely mixes with an unknown fraction of the room volume and the contaminant emitted from the source at the generation rate, S.  The remaining fraction, 1-k, of the ventilation air only mixes with the remaining (and unknown) fraction of the room volume, which does not mix with the emitted contaminant at generation rate, S (Reinke 2009a).
The mixing factor is multiplied by the ventilation rate to approximate an effective ventilation rate, which accounts for non-ideal mixing.  The effective ventilation rate, Qxk, is then substituted into Equation 2.
					Qeffective=Qxk				Eqn (3)

					C=SQeffective+Coind			Eqn (4)

Equation 4 is applied to the calculation of the formaldehyde indoor air concentration at a CWP fabrication site as follows:
      * The entire site constitutes the work space.
      * The ideal ventilation rate, Q, is equal to the total ventilation rate of the entire site.
      * The mixing factor, k, represents a fraction of the work space volume that effectively mixes with a fraction of the ventilation air and the formaldehyde emitted at generation rate, S, to result in the average indoor air concentration, C.
      * The contaminant concentration in outdoor air is equal to the mean formaldehyde concentration in ambient air for industrial land use areas according to the EPA exposure assessment (USEPA 2009b), which is equal to 6.28 ug/m[3].
      * The source generation rate, S, is the rate of formaldehyde off-gassing from the three CWP that are present at a CWP fabrication site (which is the only source considered in this assessment).  This input parameter is expressed as the product of the off-gassing emissive flux of formaldehyde (in terms of mass per time per composite wood product emitting surface area) and the emitting surface area.

					C=FxAQeffective+Coind			Eqn (5)

where:
	F	=	Emission rate (off-gassing emissive flux) of formaldehyde from the composite wood product (ug/m[2]-h); and
	A	=	Emitting surface area of the composite wood product (m[2]).

Formaldehyde off-gassing emissions from CWP decline with time, but this phenomenon is not relevant to the estimation of indoor air concentration in a CWP fabrication site because the residence time of the CWP at the site is expected to be small (days to weeks) as compared to the time required for the emission rate, F, to decline to an extent that would significantly affect the resulting indoor air concentration (weeks to months).  The concentration, C, becomes the average steady-state concentration of airborne formaldehyde due to formaldehyde off-gassing from CWP in the entire CWP fabrication site.  Section <IP_ADDRESS> discusses the input parameters in Equation 5 and their use in the mass balance equation, and the values of these parameters used are shown in Table 3-4 of that section.  The emissive flux values in Table 3-4 are derived from data in Appendix D.
1.2	Office Buildings Indoor Air Concentration Assessment Method

A mass balance approach similar to the one used for estimating formaldehyde indoor air concentration in CWP fabrication sites is used for the estimation of indoor air concentration in office buildings.  The rate of formaldehyde off-gassing from CWP components of office furniture that is expected to be present in a typical office work space is equated to the rate of exhaustion of airborne formaldehyde from this typical office work space through ventilation.  The rate of formaldehyde off-gassing from CWPs is estimated using a formaldehyde source model in which the generation rate of formaldehyde is equal to an emission rate multiplied by an emitting surface area of the office furniture expected to be present in a typical office work space.  The rate of exhaustion of indoor air formaldehyde is based on an ASHRAE outdoor air ventilation standard for this typical office work space.  Several parameters for the model, specifically emitting surface area and ventilation rate, are based on the modeling work presented in Carter and Zhang, 2007 and the BIFMA M7.1-2005 standard test method.  The remaining parameter, the emission rate, is determined using data from the EPA market profile (USEPA 2010a), similarly as was done for the CWP fabrication method, and using other assumptions and calculations described in subsection 1.2.3 and 1.2.4 below.
Carter and Zhang attempted to define a standard, representative "worst-case" office environment, in support of the BIFMA M7.1-2005 standard test method.  Carter and Zhang discussed using the BIFMA office environment model to calculate the impact of office furniture on indoor volatile organic compound (VOC) concentrations, such as formaldehyde.  Steady-state indoor airborne formaldehyde concentrations from office furniture in open work space areas and private offices are calculated from the office environment model with the following basic components:
Inputs:
Outdoor, clean air ventilation flow rate,
Surface area of composite wood products, and
Formaldehyde emission rates of composite wood products as a constant value;
Output:
Steady-state concentration at a specific time (C(t)).

The work by Carter and Zhang assumes the outdoor, clean air does not contain the VOC of interest (in this case, formaldehyde).  This exposure assessment accounts for observed concentrations of formaldehyde in ambient air.  This exposure assessment assumes the outdoor air used for office building ventilation contains formaldehyde at a concentration equal to the mean formaldehyde concentration in ambient air in commercial areas according to the EPA exposure assessment (USEPA 2009b).
1.2.1	Calculation Method

The steady-state concentration in a typical office environment due to emissions from an office workstation system or individual components may be calculated using Equation 6 (Carter and Zhang, 2007), which is based on the same mass balance principles as the mass balance model used for the CWP fabrication method:
				QC=AxE+QCocom				Eqn (6)

				C=AxEQ+Cocom					Eqn (7)

where:
      C	= 	concentration in the defined office environment at the particular time (ug/m[3]) due to a specific component;
      A 	= 	source amount in the office environment (m[2]);
      E	= 	estimated emissive flux at a particular time (ug/m[2]-h);
      Q	= 	outdoor air ventilation rate in the office environment (m[3]/h); and
      Co[com]	=	concentration of formaldehyde in the outdoor air for commercial land use areas (ug/m[3]).

The total overall concentration is calculated by summing the contribution from each component.  This summation results in the following:
				C=AixEiQ+Cocom				Eqn (8)

Here, the summation is performed over all workstation components i, where i represents each component type of the office workstation.
This model is applied to two office workstation types: open plan workstations and private office workstations.  The following subsections present the values used for the model parameters for both office workstation types.  The model parameters are:
The source amount of each workstation component, Ai, where the components are:
Panels,
Work surfaces,
Storage external surfaces;
The emissive flux of each workstation component, Ei; and
The outdoor air ventilation rate in the office workstation environment, Q.

1.2.2	BIFMA 2005 Workstation Model Parameters Ai and Q

As used in Carter and Zhang 2007, the BIFMA standard test method M7.1-2005 specifies two sets of workstation parameters based on typical open plan and private office environments.  These typical workstation parameters are for the purpose of estimating the impact of office furniture on the VOC concentrations in office spaces.  For a "typical open plan office environment of a single workstation system," BIFMA specifies:
Total workstation area dimensions: floor area of 5.94 m[2] (64 ft[2]) by 2.74 m high (9 ft high) (576 ft[3] or 16.3 m[3]);
Accounts for standard 1.83 m x 1.83 m (6 ft x 6 ft) open plan workstation system, traffic area and support space (copiers, files, storage, etc.); and
Outdoor air ventilation rate (Q) of 4.17 L/s (8.84 cfm) (minimum required ventilation rate per ASHRAE Standard 62.1-2004).

For a "typical private office environment of a single workstation system," BIFMA specifies:
Total office dimensions: floor area of 23.78 m[2] (256 ft[2]) by 2.74 m high (9 ft high) (2,304 ft[3] or 65.2 m[3]);
Accounts for standard 13.38 m[2] (144 ft[2]) private office workstation system, traffic area and support space (copiers, files, storage, etc.); and
Outdoor air ventilation rate (Q) of 9.63 L/s (20.4 cfm) (minimum required ventilation rate per ASHRAE Standard 62.1-2004).

Individual open plan and private office workstation component surface areas and outdoor air ventilation rates are tabulated in Table E-1.
Table E-1. BIFMA M7.1-2007 Standard Workstation Model Parameters
                            Workstation System Type
                 Workstation Component Type Surface Area (Ai)
                       Outdoor Air Ventilation Rate (Q)

                                  Panel Area
                               Work Surface Area
                          Storage Total External Area

                                   Open Plan
                                  11.08 m[2]
                                 (119.3 ft[2])
                                  6.103 m[2]
                                 (65.69 ft[2])
                                  4.569 m[2]
                                 (49.18 ft[2])
                                  15.0 m[3]/h
                                  (8.84 cfm)
                                Private Office
                                  7.633 m[2]
                                 (82.16 ft[2])
                                  6.734 m[2]
                                 (72.48 ft[2])
                                  10.55 m[2]
                                 (113.6 ft[2])
                                  34.7 m[3]/h
                                  (20.4 cfm)

To determine the workstation surface areas listed above in Table E-1, Carter and Zhang first determined the footprint size for all workstations present on the office building floor plans (4,594 open plan workstations and 430 private office workstations).  The 50[th] percentile workstation footprint size was taken as representative of the standard workstation size, resulting in areas of 3.34 m[2] (36 ft[2]) for an open plan workstation and 13.47 m[2] (145 ft[2]) for a private office.
Because total workstation surface areas vary within workstations of identical floor area, the 90[th] percentile conditions for total furniture surface area within the 50[th] percentile workstation footprint size were chosen to provide a representative office environment.  This resulted in 1,982 open plan workstations and 142 private offices.  Within this data set, the panel, work surface and storage surface areas were determined as a percentage of total workstation surface area and averaged, resulting in the values presented in Table E-1.
The parameter values in Table E-1 are also presented in Table 3-8 in the main body of the report.  The ventilation rate values originally presented in Carter and Zhang, 2007 were in units of L/s and cfm.  The ventilation rate values were converted to units of m[3]/h for use in the assessment method equation.
1.2.3	Formaldehyde Emissive Flux for Workstation Component Types (Ei)

The BIFMA standard and the work by Carter and Zhang do not contain any information on observed formaldehyde emission rates of actual office workstations.  Carter and Zhang provide example workstation emission rates of formaldehyde but do not discuss the statistical significance of these values such as being representative, worst case, etc.
The formaldehyde emission rate of a workstation component is a function of the type of CWP that the component is constructed of and the type of finishing, if any, for the CWP.  The finishing of CWP is the overlay of the CWP with other material that retard emissions from the surface on to which they are applied. This effect is described as barrier effectiveness, or a percent reduction of the emission rate of the CWP substrate (CPA 2003a).  The literature search did not yield any information on how the three CWPs are finished and the extent to which they are used together and in combination with other material to fabricate the various components of the workstations.  This information is needed for the estimation of representative values of the emissions rates.  Due to these data gaps, indoor air formaldehyde concentration was estimated for a range of emission rates that is derived from a what-if analysis.  For the what-if analysis, the panel and work surface components were assumed to be made entirely of a single CWP type, with the CWP type changing for each iteration of the what-if analysis.  Storage external surfaces were assumed to be constructed of materials other than CWPs with no emission of formaldehyde.  The what-if analysis follows the algorithm described in Section <IP_ADDRESS> and in Table 3-6 of the main body of the report.
For each iteration of the what-if analysis, the emissive flux of the workstation component type is calculated from the emissive flux (emission rate in units of flux) of the CWP type, extent of finishing of the component type, and barrier effectiveness chosen for the given iteration as follows:
			Ei=ECWPx1-BExFini+ECWPx1-Fini	Eqn (9)

where:
      Ei	= 	emissive flux of the workstation component type (ug/m[2]-h) (i = panels, work surfaces, or storage external surfaces);
      ECWP	= 	emissive flux of the composite wood product used to construct the workstation component type (ug/m[2]-h) (CWP = HWPW, PB, or MDF);
      BE	=	barrier effectiveness of the finishing, or overlay, of the workstation component type, expressed as a unitless fraction; and
      Fini	=	fraction of the workstation component surface area that is finished or overlayed with a barrier effectiveness of BE, expressed as a unitless fraction (i = panels, work surfaces, or storage external surfaces).

The values of ECWP used in Equation 9 are provided in Table 3-8 in the main body of the report, which are derived from the tables in Appendix D.  The values of BE are also provided in Table 3-8 in the main body of the report.  The barrier effectiveness values used to estimate the low-end and high-end concentrations were obtained from CPA (CPA 2007a).  The derivation of the intermediate value of barrier effectiveness is described in the following subsection (subsection 1.2.5) of this appendix.
1.2.4	Ambient Air Formaldehyde Concentration in Commercial Land Use Areas (Co[com])

This exposure assessment assumes the outdoor air used for office building ventilation contains formaldehyde at a concentration equal to the mean formaldehyde concentration in ambient air in commercial land use areas according to the EPA exposure assessment (USEPA 2009b).  Table 3-8 in Section <IP_ADDRESS> of the main body of the report provides the value for the concentration of formaldehyde in the outdoor air for commercial land use areas, which is 3.26 ug/m[3].
The overall equation used to calculate the formaldehyde concentration is presented in Equation 10.  Equation 10 is calculated for each iteration of the algorithm described in Section <IP_ADDRESS> of the main body of the report using the parameter values given in Table 3-8.  Recall that it is assumed storage external surfaces are not constructed of CWPs and do not emit formaldehyde.  Therefore, storage external surfaces are not included in Equation 10.
C=ECWPx1-BExFinpanels+ECWPx1-FinpanelsxApanels+ECWPx1-BExFinwork surfaces+ECWPx1-Finwork surfacesxAwork surfacesQ+Cocom         Eqn (10)

Note that the emission rates used in this analysis are for new composite wood products and do not account for the decay of emissions with time.  Therefore, this method to estimate formaldehyde exposures in office buildings only accounts for new office furniture and does not account for the decay of emission rates with time.  Data to describe the decay of emission rates with time were not identified.
1.2.5	Determination of Intermediate Value for Barrier Effectiveness

The ANSI / BIFMA M7.1-2007 standard test method specifies a full-scale chamber test method for determining VOC emissions of complete workstation systems, workstation components, and seating.  The determined emissions can then be used to estimate the impact of the workstation on the VOC concentration in a typical office environment.  The standard test method specifies a chamber ventilation rate of 12 to 20 cfm (22 to 36 m[3]/h) per workstation system during emissions testing.  BIFMA standard X7.1-2007 is a voluntary standard for meeting VOC emission limits from office furniture.  This standard specifies a formaldehyde limit of 50 ppb as measured using BIFMA M7.1-2007 for all workstation systems types.  BIFMA test method M7.1-2007 states that the background concentration of the compound of interest (such as formaldehyde) in the chamber should be measured prior to conducting the chamber test.  This background concentration is then subtracted from the measured concentration in the test chamber exhaust or return air.  Therefore, the resulting concentration, which is equated to the emission rate from the workstation divided by the chamber ventilation rate, is a net concentration due only to the workstation.  The 50 ppb formaldehyde limit is therefore the net concentration determined from the chamber test.
To define an intermediate case, EPA assumed a typical office workstation (both open plan and private office) meeting the BIFMA X7.1-2007 standard for formaldehyde.  EPA estimated that 100 percent of the workstation panel and 50 percent of the work surface area were coated with a barrier of unknown effectiveness.  These assumed values are logical bounding values.  Work surfaces are expected to be finished on their upper surface, and panels may be finished on both surfaces for aesthetic purposes.  EPA averaged the pre-baseline emission rates to estimate an average CWP emission rate for the workstation panel and work surface areas (see Appendix D for derivation of the average pre-baseline emission rate).  The parameters used are shown in Table E-2.
Since chamber testing requires that the net formaldehyde concentration be used to determine the emissions from the workstation, the ambient air concentration is subtracted from Equation 10 presented in the previous subsection 1.2.4.  The net formaldehyde concentration, C[net], is then used instead in the left-hand side of Equation 10.  This new equation is presented below and is solved for the intermediate barrier effectiveness using the values for concentration and each parameter given in Table E-2.
Cnet=ECWPx1-BExFinpanels+ECWPx1-FinpanelsxApanels+ECWPx1-BExFinwork surfaces+ECWPx1-Finwork surfacesxAwork surfacesQ 	Eqn (11)

Table E-2. Parameters Used to Determine Intermediate Barrier Effectiveness
                                   Parameter
                                     Value
                                    Source
Net Formaldehyde Concentration in Chamber
61.5 ug/m[3]
BIFMA X7.1-2007 standard for formaldehyde (unit converted from 50 ppb)
Panel Emission Rate
306.7 ug/m[2]-h
Weighted average of domestic and import pre-baseline emission rates, averaged over all three CWP types (see Section 3 and Appendix D)
Work Surface Emission Rate
306.7 ug/m[2]-h

Storage Panel Emission Rate
0 ug/m[2]-h
Carter 2007a
Panel Area
11.08 m[2] (open plan)
7.633 m[2] (private office)
Carter 2007a
Percent Panel Area with Barrier
100%
EPA Assumption
Work Surface Area
6.1 m[2] (open plan)
6.734 m[2] (private office)
Carter 2007a
Percent Work Surface Area with Barrier
50%
EPA Assumption
Storage Panel Surface Area
4.57 m[2] (open plan)
10.55 m[2] (private office)
Carter 2007a
Storage Panel Surface Area with Barrier
N/A
EPA Assumption
Ventilation Rate
36 m[3]/h
The high-end ventilation rate for chamber testing specified in BIFMA M7.1-2007
N/A  -  Not applicable

The intermediate barrier effectiveness calculated from the parameters for the open plan and private office workstations were 71 percent and 65 percent, respectively.  These intermediate barrier effectiveness values were used for all intermediate indoor air concentration calculations for open plan and private office workstations following the algorithm outlined in Section <IP_ADDRESS> and Table 3-6 in the main body of the report.
1.3	Calculation of ADC and LADC from Model Results for CWP Fabrication and Office Buildings

Model results from Equation 5 and Equation 10 above are inputs to estimate ADC and LADC.  The average daily concentration (ADC) and lifetime-average daily concentration (LADC) are calculated from the concentration for each modeled scenario outlined in Section 3 of the main body of the report for each baseline and analytical-option scenario.  ADC and LADC are calculated from Equation 12 (EPA 2009a).
					EC=CxEDxEFxWYAT				Eqn (12)

where:
      EC	=	Exposure concentration (μg/m[3]);
      C	=	Contaminant concentration in air (μg/m[3]);
      ED	=	Exposure duration (hr/day; default: 8);
      EF	=	Exposure frequency (days/yr; default: 250);
      WY	=	Working years per lifetime (years; ADC and LADC: 40 years); and
      AT	=	Averaging time (lifetime in years x 365 days/yr x 24 hours/day; ADC: 40 years, LADC: 70 years).

1.4	Dermal Exposure Assessment Method for All Life Cycle Stages

EPA has two general categories of assessing dermal exposure when measurements are not available: (1) quantitative dermal exposure models and (2) qualitative dermal exposure assessments.  Both categories of dermal exposure assessments are discussed below.  EPA has developed a series of standard models for quantitatively estimating worker dermal exposures to liquid and solid chemicals during various types of activities.  To estimate dermal exposure, all of these dermal exposure models assume a specific surface area of the skin that is contacted by a material containing the chemical of interest, as well as a specific surface density of the material on the skin.
EPA has developed a series of standard models for quantitatively estimating worker dermal exposures to liquid and solid chemicals during various types of activities.  To estimate dermal exposure, all of these dermal exposure models assume a specific surface area of the skin that is contacted by a material containing the chemical of interest, as well as a specific surface density of the material on the skin.  The models also assume no use of controls or gloves to reduce the exposure.  These assumptions and default parameters are defined based on the nature of the exposure (e.g., one hand or two hand, immersion in material, contact with surfaces).  The standard EPA dermal model equation is shown in Equation 13 (USEPA 1991a; USEPA 2000b).
		EXPdermal=AREAsurfacexQremain_skinxFchemxNevent	Eqn (13)

where:
      EXPdermal	=	Dermal exposure to the liquid or solid chemical per day (mg chemical/worker-day);
      AREAsurface	=	Surface area of the skin that is in contact with liquid or solid material containing the chemical (840 cm[2]; EPA/OPPT 2-Hand Dermal Contact with Liquid Model);
      Qremain_skin	=	Quantity of the liquid or solid material containing the chemical that remains on the skin after contact (0.7-2.1 mg/cm[2]-event; EPA/OPPT 2-Hand Dermal Contact with Liquid Model);
      Fchem	=	Weight fraction of the chemical of interest in the material being handled in the activity; and
      Nevent	=	Frequency of events for the activity (EPA default = 1 event/worker-day).

Dermal doses in this report are estimated in units further normalized by worker body weight, as indicated in Equation 14:
			EXPdermal_bw=EXPdermalBWworker			Eqn (14)

where:
      EXPdermal_bw	=	Dermal exposure to the liquid or solid chemical per day normalized by worker body weight (mg chemical/kg-day);
      EXPdermal	=	Dermal exposure to the liquid or solid chemical per day (mg chemical/worker-day); and
      BWworker	=	Body weight of an average worker (kg; EPA default value = 70 kg (USEPA 1997a).

For several categories of exposure, EPA uses qualitative assessments to estimate dermal exposure.  Table E-4 summarizes these categories and the resulting qualitative dermal exposure assessments.  Where chemicals were monomers that had been reacted or additives that would not likely to be released from a resin matrix, dermal exposures are characterized as not quantifiable.

Table E-3. Standard EPA Default Values for Use in the Worker Dermal Exposure Models
                                 Default Model
                              Example Activities
                                AREAsurface[a]
                                    (cm[2])
                                Qremain_skin[b]
                               (mg/cm[2]-event)
                               Resulting Contact
                          AREAsurface x Qremain_skin
                                  (mg/event)
Physical Form: Liquids
  EPA/OPPT 1-Hand Dermal Contact with Liquid Model
Liquid sampling activities
Ladling liquid/bench-scale liquid transfer
                                      420
                                 (1 hand mean)
                                   Low: 0.7
                                   High: 2.1
                                   Low: 290
                                   High: 880
  EPA/OPPT 2-Hand Dermal Contact with Liquid Model
Maintenance
Manual cleaning of equipment and containers
Filling drum with liquid
Connecting transfer line
                                      840
                                 (2 hand mean)
                                   Low: 0.7
                                   High: 2.1
                                   Low: 590
                                  High: 1,800
  EPA/OPPT 2-Hand Dermal Immersion in Liquid Model
Handling wet surfaces
Spray painting
                                      840
                                 (2 hand mean)
                                   Low: 1.3
                                  High: 10.3
                                  Low: 1,100
                                  High: 8,650
Physical Form: Solids
  EPA/OPPT 2-Hand Dermal Contact with Container Surfaces Model
Handling bags of solid materials (closed or empty)
                                  No defaults
                                  No defaults
                                  < 1,100c
  EPA/OPPT 2-Hand Dermal Contact with Solids Model
Solid sampling activities
Filling/dumping containers of powders, flakes, granules
Weighing powder/scooping/mixing (i.e., dye weighing)
Cleaning solid residues from process equipment
Handling wet or dried material in a filtration and drying process
                                  No defaults
                                  No defaults
                                 < 3,100[c]
   a - These default values were adopted in the 2000 EPA report on screening-level dermal exposure estimates (USEPA 2000b) and are the mean values for men taken from the EPA Exposure Factors Handbook, 1997 (USEPA 1997a).
   b - These default values were adopted in the 2000 EPA report on screening-level dermal exposure estimates (USEPA 2000b). The report derived the selected ranges of values for liquid handling activities from: U.S. EPA. A Laboratory Method to Determine the Retention of Liquids on the Surface of Hands. U.S. Environmental Protection Agency, Office of Pollution Prevention and Toxics, Exposure Evaluation Division. EPA 747-R-92-003. September 1992.
   c - These default values were adopted in the 2000 EPA report on screening-level dermal exposure estimates (USEPA 2000b). The report derived values for dermal contact for solids handling activities from: Lansink, C.J.M., M.S.C. Breelen, J. Marquart, and J.J. van Hemmen: Skin Exposure to Calcium Carbonate in the Paint Industry. Preliminary Modeling of Skin Exposure Levels to Powders Based on Field Data (TNO Report V 96.064). Rijswijk, The Netherlands: TNO Nutrition and Food Research Institute, 1996.

Table E-4. EPA Default Qualitative Assessments for Screening-Level Estimates of Dermal Exposure
                                   Category
                               Dermal Assessment
Corrosive substances (pH>12, pH<2)
Negligible
Materials at temperatures >140F (60C)
Negligible
Cast Solids (e.g., molded plastic parts, extruded pellets)
Non-Quantifiable (Some surface contact may occur if manually transferred)
"Dry" surface coatings (e.g., fiber spin finishes, dried paint)
Non-Quantifiable (If manual handling is necessary and there is an indication that the material may abrade from the surface, quantify contact with fingers/palms as appropriate)
Gases/Vapors
Non-Quantifiable (Some contact may occur in the absence of protective clothing)
  Source: USEPA 1991a

3.0	Converting Units of Concentration

This section presents the methodology for converting between airborne concentrations measured in volume- or mole-based parts-per million (ppm) and airborne concentrations measured in micrograms per cubic meter (ug/m[3]).  This assessment conducts exposure and dose calculations using concentrations in mg/m[3] or ug/m[3] depending on the magnitude of the values.  This section presents concentration units in ug/m[3].
To convert the units of concentration between a volume- or mole-based ppm to ug/m[3] at ambient room conditions, it is assumed that the ideal gas law applies to a mixture of formaldehyde and air at ambient conditions.  The mass-based concentration of formaldehyde in air from the ideal gas law is solved for as follows:
	C=mV=yPMRTx1,000,000μggx1,000molkmol	Eqn (15)

where:
      C	=	formaldehyde concentration (ug/m[3]);
      m	=	total mass of formaldehyde (ug);
      V	=	total volume of gas (m[3]);
      y	=	mole fraction of formaldehyde (mol/mol);
      P	=	total pressure (atm);
      M	=	molecular weight of formaldehyde (g/mol);
      R	=	universal gas constant (m[3]-atm/kmol-K); and
      T	=	temperature (K).

Here, the mole fraction of formaldehyde, y, is equal to the formaldehyde concentration in parts-per million (ppm) divided by one million.  At ambient conditions (1 atm and 298 K), with a formaldehyde molecular weight of 30.03 g/mol and a gas constant of 0.082 m[3]-atm/kmol-K, the unit conversion is 1,229 ug/m[3] per ppm of formaldehyde.
4.0	ASTM E1333 Large Chamber Test Method

In this assessment, an equation is needed to calculate emission rates from the methods used to measure them.  In this assessment, the ASTM E1333 large chamber test method is used to convert between chamber-test measured formaldehyde concentrations (emission levels) and emission rates.  The equation used is Equation 15 below.  This subsection presents some general background information on chamber test methods and then describes the ASTM E1333 large chamber test method.
The standard method for measuring emissions from composite wood products is to use a test chamber (Kim 2007a).  The chamber method is based on a mass balance approach that measures the mass flow rates of formaldehyde entering and leaving the chamber system at steady-state (Hodgson 2007a).  Standard chamber methods are either referred to as the large or small chamber method based on the specified chamber size.  In general, common large chamber methods for estimating formaldehyde emissions require minimum chamber sizes between 10 to 22 cubic meters.  In addition to chamber size, large chamber methods specify several test parameters, including the loading ratio, air exchange rate, chamber temperature and humidity.  This section discusses the ASTM E1333 large chamber test method.
The ASTM E1333 has been used by the composite wood product industry for establishing compliance of their products with the U.S. Department of Housing and Urban Development (HUD) and ANSI standards for formaldehyde emissions (Hodgson 2007a).  It is also the reference test method specified in CARB's regulation.  The purpose of ASTM E1333 is to measure the formaldehyde concentration in air and the emission rate from a number of large test samples (composite wood products) containing formaldehyde under conditions designed to simulate product use.  ASTM E1333 is primarily used for testing newly manufactured panel products (ASTM 2002a).  Prior to testing, this method requires test samples to be conditioned for seven days.  During conditioning, the samples must be placed in a manner such that there is a minimum of six-inch spacing in-between the panels.  The conditioning is followed by a 16- to 20- hour exposure period in a large-scale chamber.  The chamber is operated at specific product loading ratios and an air exchange rate that are typical of the indoor environment.  Air samples are taken from the chamber at steady-state conditions and the formaldehyde concentration is analyzed.  Table E-5 lists the product-specific loading ratios for the composite wood products of interest.  Table E-6 lists the test parameters for ASTM E1333.
Table E-5.  ASTM E1333 Loading Ratios for Hardwood Plywood, Medium-Density Fiberboard, and Particleboard
                            Composite Wood Product
                               Loading Ratio (L)

                                  ft[2]/ft[3]
                                   m[2]/m[3]
Hardwood plywood
                                     0.13
                                     0.43
Medium-density fiberboard
                                     0.08
                                     0.26
Particleboard
                                     0.13
                                     0.43

Table E-6.  Specified Parameters for ASTM E1333
                                Test Parameter
                               ASTM E1333 Value
Loading Ratio (m[2]/m[3]) (L)
                                 See Table E-5
Minimum Chamber Size (m[3])
                                     22.7
Temperature (°C)
                                    25 +-1
Relative Humidity (%)
                                    50 +-4
Air Exchange Rate (h[-1]) (n)
                                  0.5 +-0.05
Edge Sealing
                                     None
Conditioning
                                7 days +-3 hrs
Test Duration
                                 16 to 20 hrs

The emission rate of formaldehyde is dependent on several parameters.  At steady-state conditions, the emission rate (ER) or area-specific emission rate of formaldehyde in ug/m[2]-h is calculated as:
				ER=VAxnxCnet				Eqn (16)

where:
      V	=	chamber volume (m[3]);
      n	=	chamber air exchange rate (h[-1]);
      C[net]	=	net formaldehyde chamber concentration (ug/m[3]); and
      A	=	total surface area of sample (m[2]).

The emission rate represents the flux of formaldehyde or the mass of formaldehyde emitted per unit area of wood material per time (ug/m[2]-h).  As seen in Equation 16, the emission rate is a function of the chamber volume, V, and test sample surface area, A.  The ratio of these parameters is often specified in a large chamber method in terms of a "loading ratio."  Loading ratios (L) are calculated as the emitting surface area of the wood sample divided by the chamber volume (m[2]/m[3]):
					L=AV,   or    A=LxV			Eqn (17)

Substituting Equation 17 into Equation 16 yields Equation 18, which is used to calculate emission rates from the measured net formaldehyde chamber concentration (emission level) using the parameters given in Table E-5 and Table E-6.
					ER=nxCnetL					Eqn (18)

In chamber methods, air is continuously circulated inside the test environment.  The area-specific air flow rate (m3/m2-h or m/h) is the ratio between the air flow rate Q (m3/h) entering the chamber and the total surface area, A, of the test sample.  The area-specific air flow rate is also calculated as the product of the chamber volume, V, and the air exchange rate, n, divided by the test sample surface area as follows.
					QA=VxnA					Eqn (19)

Substituting Equation 17 into 19, the area-specific air flow rate may be expressed as a quotient of n/L.
					QA=VxnLxV=nL	 			Eqn (20)

After steady-state conditions are achieved, a minimum of two air samples are taken from the chamber at a rate of 1+-0.05 L/min for 60 minutes +-5 seconds.  The quantity of formaldehyde in the sample is determined by an adaptation of the National Institute for Occupational Safety and Health (NIOSH) 3500 chromotropic acid test procedure (ASTM 2002a), where air is bubbled through a 1-percent sodium bisulfite solution and analyzed using a UV-Vis spectrophotometer.

Appendix F
PRE-BASELINE FORMALDEHYDE EXPOSURES FROM OSHA IMIS BY WORKER ACTIVITY AND INDUSTRY SECTOR FOR COMPOSITE WOOD PRODUCT FABRICATORS
                            BACKGROUND ON IMIS DATA

IMIS is designed to collect, process, retrieve, and communicate penalty assessment, arbitration, and collection information regarding OSHA inspections.  For each data point, the database contained information on the following data elements:
Inspection date;
Identity of inspected facility;
Inspection type (e.g., inspection in response to a complaint, referral, or as part of a program);
Worker job description;
Exposure concentration;
Exposure concentration measurement type (personal or area monitoring);
Exposure type (i.e., time weighted average (TWA) or peak exposure);
Frequency or duration of exposure;
Number of employees at the inspected facility;
Number of employees exposed; and
Applicable OSHA PEL.
OSHA IMIS data for most of the NAICS codes given in Table 2-1 were obtained from OSHA in June 2010.  The OSHA occupational exposure limits for formaldehyde are given in Appendix C.
The "exposure types" for the obtained data include TWA, STEL, ceiling, peak exposures or not detected or not found.  Only TWA data were used to develop exposure estimates (in terms of average daily concentrations (ADCs) and lifetime-average daily concentrations (LADCs)).  STEL, ceiling, and peak measurements are not representative of daily average concentration levels and were therefore excluded (refer to Appendix A for a definition of these terms).  Also, measurements that resulted in a non-detected formaldehyde concentration do not include their measurement type in the OSHA IMIS database (i.e., TWA or STEL measurement type).  Therefore, it is unknown whether a non-detected value was the result of a measurement over an extended duration of time for the purpose of determining TWA exposure or measurement over a fifteen-minute duration.  For this reason, non-detected and not-found results were excluded except as discussed below.
Additionally, only personal monitoring data were included in the assessment except in the case of the retail life cycle stage.  IMIS contains few personal monitoring data from 2002 and onward for this life cycle stage, and the inclusion of area monitoring data approximately doubled the number of included data points.  Most of these area monitoring data have non-detect values.  Area monitoring data in a strictly retail setting are considered representative of potential worker exposure and are expected to be TWA data.  The non-detected value was set equal to the lowest reliable quantitation limit (RQL) identified among OSHA's sampling and analysis methods for formaldehyde.  The RQL was identified as 0.00058 ppm (OSHA 2010b).  Also, any detected values for all life cycle stages less than this RQL were set equal to the RQL.

Grouping Data by Worker Activity

This appendix presents a summary of OSHA IMIS data for CWP fabrication industry sectors grouped by their worker activity.  This grouping was performed as part of this exposure assessment to provide perspective as to the different worker activities monitored by OSHA and to present statistics of the monitoring data according to worker activity.  There is some uncertainty about the worker activities recorded in IMIS.  The worker activities were not recorded or identified in a consistent manner in IMIS.  For example, for CWP fabrication, gluing activities are identified as "apply wood glue" and "glue machine operator".  Therefore, this appendix presents OSHA IMIS data grouped such that similar worker activities are grouped into a single worker activity category.  Additionally, some worker activities are similar or can be expected to result in similar exposures, such as "sawing", "routing", and "cutting", and are compiled into a single category.  Other worker activities are compiled into a single category due to uncertainty in the exact job description, such as "wood worker", "laborer", or "operator".  Table F-1 presents a summary of the TWA, personal monitoring data from OSHA IMIS for CWP fabrication organized by worker activity description categories.

Table F-1.  Pre-Baseline Formaldehyde Exposures by Organized by Worker Activity Category for Composite Wood Product Fabricators from OSHA IMIS
                                   Industry
                          Worker Activity Description
                           Number of Sites Monitored
                             Number of Data Points
                  Monitored Formaldehyde Concentration (ppm)
                Monitored Formaldehyde Concentration (mg/m[3])
                                     Year
                      Description of Concentration Level
Wood Kitchen Cabinets and Countertop Manufacturing
Painting / Laminating / Finishing / Spraying
                                      14
                                      22
                                     0.69
                                     0.85
                                     2003
Maximum

                                     0.15
                                     0.18
                                  2004, 2007
Median

                                    0.0006
                                     0.001
                                     2004
Minimum

Fabricating / Assembling / Building
                                       1
                                       1
                                      0.2
                                     0.25
                                     2004
1 Data Point

Other Operations / Maintenance
                                       1
                                       2
                                     0.52
                                     0.639
                                     2004
Maximum

                                     0.28
                                     0.343
                                  2004, 2004
Median

                                     0.038
                                     0.047
                                     2004
Minimum

Sawing / Cutting / Routing
                                       1
                                       2
                                     0.070
                                     0.086
                                     2005
Maximum

                                     0.054
                                     0.066
                                  2005, 2005
Median

                                     0.037
                                     0.046
                                     2005
Minimum

Sanding
                                       1
                                       1
                                     0.035
                                     0.043
                                     2003
1 Data Point

Compliance, Safety, and Health Officer
                                       1
                                       1
                                     0.025
                                     0.031
                                     2006
1 Data Point
Upholstered Household Furniture Manufacturing
Painting / Laminating / Finishing / Spraying
                                       1
                                       2
                                     0.092
                                     0.11
                                     2004
Maximum

                                     0.06
                                     0.074
                                  2004, 2004
Median

                                     0.028
                                     0.034
                                     2004
Minimum

Other Operations / Maintenance
                                       2
                                       3
                                     0.11
                                     0.137
                                     2003
Maximum

                                     0.04
                                     0.049
                                     2004
Median

                                     0.04
                                     0.049
                                     2004
Minimum

Gluing
                                       1
                                       1
                                     0.009
                                     0.011
                                     2003
1 Data Point
Nonupholstered Household Furniture Manufacturing
Painting / Laminating / Finishing / Spraying
                                       8
                                      10
                                     0.59
                                     0.73
                                     2004
Maximum

                                     0.330
                                     0.405
                                  2008, 2007
Median

                                     0.031
                                     0.038
                                     2008
Minimum

Fabricating / Assembling / Building
                                       1
                                       1
                                     0.22
                                     0.27
                                     2007
1 Data Point

Other Operations / Maintenance
                                       1
                                       5
                                    0.1129
                                     0.139
                                     2009
Maximum

                                    0.0625
                                     0.077
                                     2009
Median

                                    0.0278
                                     0.034
                                     2009
Minimum

Compliance, Safety, and Health Officer
                                       3
                                       3
                                     0.14
                                     0.172
                                     2008
Maximum

                                     0.089
                                     0.109
                                     2009
Median

                                    0.0712
                                     0.088
                                     2008
Minimum
Wood Office Furniture Manufacturing
Painting / Laminating / Finishing / Spraying
                                       4
                                       8
                                     0.58
                                     0.713
                                     2004
Maximum

                                     0.055
                                     0.068
                                  2004, 2005
Median

                                     0.009
                                     0.011
                                     2004
Minimum

Fabricating / Assembling / Building / Laboring
                                       1
                                       1
                                     0.02
                                     0.025
                                     2004
1 Data Point

Other Operations / Maintenance
                                       1
                                       2
                                     0.04
                                     0.049
                                     2005
Maximum

                                    0.03135
                                     0.039
                                  2005, 2005
Median

                                    0.0227
                                     0.028
                                     2005
Minimum

Sawing / Cutting / Routing
                                       2
                                       4
                                     0.067
                                     0.082
                                     2004
Maximum

                                     0.049
                                     0.060
                                  2004, 2004
Median

                                    0.0048
                                     0.006
                                     2004
Minimum

Sanding
                                       1
                                       3
                                     0.028
                                     0.034
                                     2005
Maximum

                                     0.027
                                     0.033
                                     2005
Median

                                    0.0219
                                     0.027
                                     2005
Minimum
Institutional Furniture Manufacturing
Painting / Laminating / Finishing / Spraying
                                       3
                                       3
                                     0.21
                                     0.258
                                     2005
Maximum

                                     0.06
                                     0.074
                                     2007
Median

                                    0.0189
                                     0.023
                                     2002
Minimum

Other Operations / Maintenance
                                       2
                                       3
                                     0.10
                                     0.123
                                     2007
Maximum

                                     0.06
                                     0.074
                                     2007
Median

                                     0.01
                                     0.012
                                     2002
Minimum
Showcase, Partition, Shelving, and Locker Manufacturing
Painting / Laminating / Finishing / Spraying
                                       2
                                       3
                                     0.228
                                     0.280
                                     2004
Maximum

                                     0.216
                                     0.265
                                     2004
Median

                                     0.13
                                     0.160
                                     2005
Minimum

Press Operating
                                       1
                                       2
                                     0.187
                                     0.230
                                     2004
Maximum

                                     0.138
                                     0.169
                                  2004, 2004
Median

                                     0.088
                                     0.108
                                     2004
Minimum

Compliance, Safety, and Health Officer
                                       1
                                       1
                                     0.184
                                     0.226
                                     2004
1 Data Point
Custom Architectural Woodwork and Millwork Manufacturing
Other Operations / Maintenance
                                       1
                                       3
                                       1
                                     1.229
                                     2008
Maximum

                                     0.44
                                     0.541
                                     2008
Median

                                     0.04
                                     0.049
                                     2008
Minimum

Sawing / Cutting / Routing
                                       1
                                       1
                                     0.068
                                     0.084
                                     2004
1 Data Point
Other Millwork (including flooring) Manufacturing
Painting / Laminating / Finishing / Spraying
                                       1
                                       1
                                     0.13
                                     0.160
                                     2003
1 Data Point

Fabricating / Assembling / Building / Laboring
                                       1
                                       2
                                     0.075
                                     0.092
                                     2002
Maximum

                                    0.03805
                                     0.047
                                  2002, 2002
Median

                                    0.0011
                                     0.001
                                     2002
Minimum

Other Operations / Maintenance
                                       2
                                       3
                                     0.243
                                     0.299
                                     2006
Maximum

                                     0.184
                                     0.226
                                     2006
Median

                                    0.0992
                                     0.122
                                     2002
Minimum

Sawing / Cutting / Routing
                                       1
                                       1
                                     0.05
                                     0.061
                                     2004
1 Data Point

Press Operating
                                       2
                                       3
                                     0.55
                                     0.676
                                     2008
Maximum

                                     0.317
                                     0.390
                                     2008
Median

                                     0.06
                                     0.074
                                     2004
Minimum
Wood Window and Door Manufacturing
Painting / Laminating / Finishing / Spraying
                                       1
                                       1
                                    0.00438
                                     0.005
                                     2007
1 Data Point

Fabricating / Assembling / Building / Laboring
                                       2
                                       2
                                     0.24
                                     0.295
                                     2006
Maximum

                                    0.1465
                                     0.180
                                  2006, 2009
Median

                                     0.053
                                     0.065
                                     2009
Minimum
Motor Home Manufacturing
Trailer Cleaning
                                       1
                                       1
                                    0.0023
                                     0.003
                                     2002
1 Data Point
All Other Miscellaneous Wood Product Manufacturing
All Activities
                                       8
                                      18
                                     1.00
                                     1.229
                                     2005
Maximum

                                     0.144
                                     0.177
                                  2005, 2006
Median

                                     0.003
                                     0.003
                                     2003
Minimum

Table F-2 through Table F-12 present summary statistics of the TWA, personal monitoring data from OSHA IMIS by NAICS code for the CWP fabrication life cycle stage.  Not all NAICS codes within CWP fabrication are included in this summary; only NAICS codes for which data were obtained from OSHA IMIS.

Table F-2.  Summary Statistics for Pre-Baseline Monitoring Data for NAICS Code 321911

                     Monitored Formaldehyde Concentration
                           Number of Monitored Sites
                             Number of Data Points
                                     Year

                                     (ppm)
                                  (ug/m[3])

Maximum
                                     0.24
                                     295.0
                                       3
                                       3
                                     2006
Median
                                     0.053
                                     65.1

                                     2009
Minimum
                                    0.0044
                                      5.4

                                     2007
Mean
                                     0.099
                                     121.8

                                      N/A
Standard deviation
                                     0.124
                                     152.9

                                      N/A

Table F-3.  Summary Statistics for Pre-Baseline Monitoring Data for NAICS Code 321918

                     Monitored Formaldehyde Concentration
                           Number of Monitored Sites
                             Number of Data Points
                                     Year

                                     (ppm)
                                  (ug/m[3])

Maximum
                                     0.55
                                     676.0
                                       6
                                      10
                                     2008
Median
                                    0.1146
                                     140.8

                                      N/A
Minimum
                                    0.0011
                                      1.4

                                     2002
Mean
                                    0.17093
                                     210.1

                                      N/A
Standard deviation
                                     0.164
                                     201.6

                                      N/A

Table F-4.  Summary Statistics for Pre-Baseline Monitoring Data for NAICS Code 337110

                     Monitored Formaldehyde Concentration
                           Number of Monitored Sites
                             Number of Data Points
                                     Year

                                     (ppm)
                                  (ug/m[3])

Maximum
                                     0.69
                                     848.0
                                      16
                                      29
                                     2003
Median
                                     0.137
                                     168.4

                                     2004
Minimum
                                    0.0006
                                      0.7

                                     2004
Mean
                                     0.197
                                     242.6

                                      N/A
Standard deviation
                                     0.204
                                     250.9

                                      N/A

Table F-5.  Summary Statistics for Pre-Baseline Monitoring Data for NAICS Code 337121

                     Monitored Formaldehyde Concentration
                           Number of Monitored Sites
                             Number of Data Points
                                     Year

                                     (ppm)
                                  (ug/m[3])

Maximum
                                     0.111
                                     136.6
                                       3
                                       6
                                     2003
Median
                                     0.040
                                     49.2

                                      N/A
Minimum
                                     0.009
                                     11.1

                                     2003
Mean
                                     0.053
                                     65.6

                                      N/A
Standard deviation
                                     0.039
                                     48.5

                                      N/A

Table F-6.  Summary Statistics for Pre-Baseline Monitoring Data for NAICS Code 337122

                     Monitored Formaldehyde Concentration
                           Number of Monitored Sites
                             Number of Data Points
                                     Year

                                     (ppm)
                                  (ug/m[3])

Maximum
                                     0.590
                                     725.1
                                      11
                                      19
                                     2004
Median
                                     0.170
                                     208.9

                                     2008
Minimum
                                     0.028
                                     34.2

                                     2009
Mean
                                     0.222
                                     273.4

                                      N/A
Standard deviation
                                     0.182
                                     223.7

                                      N/A

Table F-7.  Summary Statistics for Pre-Baseline Monitoring Data for NAICS Code 337127

                     Monitored Formaldehyde Concentration
                           Number of Monitored Sites
                             Number of Data Points
                                     Year

                                     (ppm)
                                  (ug/m[3])

Maximum
                                     0.210
                                     258.1
                                       3
                                       6
                                     2005
Median
                                     0.060
                                     73.7

                                      N/A
Minimum
                                     0.010
                                     12.1

                                     2002
Mean
                                     0.076
                                     94.0

                                      N/A
Standard deviation
                                     0.073
                                     89.8

                                      N/A

Table F-8.  Summary Statistics for Pre-Baseline Monitoring Data for NAICS Code 337211

                     Monitored Formaldehyde Concentration
                           Number of Monitored Sites
                             Number of Data Points
                                     Year

                                     (ppm)
                                  (ug/m[3])

Maximum
                                     0.580
                                     712.8
                                       6
                                      18
                                     2004
Median
                                     0.029
                                     35.6

                                      N/A
Minimum
                                     0.005
                                      5.9

                                     2004
Mean
                                     0.082
                                     100.9

                                      N/A
Standard deviation
                                     0.140
                                     171.5

                                      N/A

Table F-9.  Summary Statistics for Pre-Baseline Monitoring Data for NAICS Code 337212

                     Monitored Formaldehyde Concentration
                           Number of Monitored Sites
                             Number of Data Points
                                     Year

                                     (ppm)
                                  (ug/m[3])

Maximum
                                     1.00
                                     1229
                                       2
                                       4
                                     2008
Median
                                     0.25
                                     312.2

                                      N/A
Minimum
                                     0.04
                                     49.2

                                     2008
Mean
                                     0.39
                                     475.6

                                      N/A
Standard deviation
                                     0.45
                                     550.0

                                      N/A

Table F-10.  Summary Statistics for Pre-Baseline Monitoring Data for NAICS Code 337215

                     Monitored Formaldehyde Concentration
                           Number of Monitored Sites
                             Number of Data Points
                                     Year

                                     (ppm)
                                  (ug/m[3])

Maximum
                                     0.23
                                      280
                                       3
                                       6
                                     2004
Median
                                     0.19
                                     228.0

                                      N/A
Minimum
                                     0.09
                                     108.2

                                     2004
Mean
                                     0.17
                                     211.6

                                      N/A
Standard deviation
                                     0.05
                                     65.6

                                      N/A

Table F-11.  Summary Statistics for Pre-Baseline Monitoring Data for NAICS Code 336213

                     Monitored Formaldehyde Concentration
                           Number of Monitored Sites
                             Number of Data Points
                                     Year

                                     (ppm)
                                  (ug/m[3])

Single Data Point
                                    0.0023
                                      2.8
                                       1
                                       1
                                     2002

Table F-12.  Summary Statistics for Pre-Baseline Monitoring Data for NAICS Code 321999

                     Monitored Formaldehyde Concentration
                           Number of Monitored Sites
                             Number of Data Points
                                     Year

                                     (ppm)
                                  (ug/m[3])

Maximum
                                     1.00
                                     1229
                                       8
                                      18
                                     2005
Median
                                     0.14
                                     177.0

                                      N/A
Minimum
                                     0.003
                                      3.4

                                     2003
Mean
                                     0.20
                                     249.6

                                      N/A
Standard deviation
                                     0.26
                                     313.6

                                      N/A

Appendix G
SUMMARY OF OSHA INSPECTION REPORTS
ONE DATA GAP OF THE EXPOSURE ASSESSMENT IS THE USE OF PERSONAL PROTECTIVE EQUIPMENT (PPE) in manufacturing facilities.  To help resolve this data gap, OSHA inspection reports associated with the obtained OSHA IMIS data were obtained from OSHA.  This appendix summarizes the PPE information found in the reports received as of January 2011.
Table G-1 and the following sections present the findings of the review of the inspection reports received.
Table G-1.  Summary of OSHA Inspection Reports and Findings on PPE Use
                          Name of Inspected Facility
     Personal Protective Equipment (PPE) Worn by Workers During Inspection
                       Respirator Use During Inspection
Manufacturing
Carolina Curves
Inspection No. 303713325
Ear plugs, safety glasses/goggles, aprons
No
McKnight Plywood
Inspection No. 123445595
Safety glasses, rubber gloves, back braces
No
Marshfield Door Systems
Inspection No. 303864029
Safety glasses, gloves
No
Fiberesin Industries
Inspection No. 307061689
Safety glasses, gloves, eye protection
No
Unilin Flooring NC, LLC
Inspection No. 312479835
3M 6300 half mask with formaldehyde cartridges
Yes
Composite Wood Product Fabrication
Plymart Inc.
Inspection No. 308245372
Unknown
No
Bushline Inc.
Inspection No. 306132275
Half face air purifying respirator
Yes
England Inc.
Inspection No. 307674051
Safety glasses, smock, hearing protection
No
Commercial Furniture Group
Inspection No. 311144059
Safety glasses and hearing protection
No
Harris Tarkett
Inspection No. 307206987
Safety glasses, gloves, and hearing protection
No
Gunlocke Company
Inspection No. 307690578
Unknown
No
Armstrong Cabinets
Inspection No. 306021239
Gloves, apron
No
Wood Goods Industries, Inc.
Inspection No. 307041707
Respirator with organic vapor cartridge, nitrile gloves, safety glasses, hard hat, ear plugs, and steel toe shoes
Yes (not required)
Parenti & Rafaelli, Ltd
Inspection No. 305228652
Safety glasses, steel toe shoes, gloves, and half-face respirators. Dust masks are also available for use.
Yes
Benvenuti and Stein
Inspection No. 312188972
Half-face cartridge respirator, safety glasses, safety shoes
Yes
Ameriwood Industries Inc.
Inspection No. 311606883
Safety glasses, ear plugs
No
Tru-Wood Cabinets, Inc.
Inspection No. 307013250
Safety glasses, earplugs
No
Jimson Manufacturing Co.
Inspection No. 303424014
Safety glasses
No
Newood Display Fixtures Manufacturing Company
Inspection No. 304064835
Respirator
Yes
Simple Designs Manufacturing
Inspection No. 306629171
Safety glasses, gloves, ear protection; dust masks are "available for use"
No

1.0	Manufacturing

Carolina Curves Inc., Inspection 303713325
The inspection occurred as a result of referral. Carolina is primarily engaged in the manufacture of curved plywood products for the furniture industry (e.g., chairs, bed posts, and other furniture items). These operations include receiving plywood, laminated veneer using an amino resin containing formaldehyde (0.1  -  0.5%), mold pressing of veneer (using pressure/Rf to curve plywood), wood cutting, sanding, shaping operations. Inspection of the curved wood products is the final phase of the curved plywood operation prior to shipping. According to the air sampling reports, workers may wear ear plugs, safety glasses/goggles and aprons as PPE. These reports did not indicate the use of a respirator during any of the inspected activity.
McKnight Plywood, Inspection 123445595
This inspection was a planned health inspection. McKnight Plywood makes laminated hardwood plywood products such as hardwood flooring using purchased veneers and formaldehyde-based glues (0.21% formaldehyde in the glue used in the old building and 0.32% in the glue used in the flooring plant). Some of the operations at McKnight Plywood include plywood sorting, glue application, pressing, cooling, cutting and sanding the finished products.
OSHA cited the facility for formaldehyde overexposure. However, based on the inspection summary and the air sampling reports, the only PPE worn at the facility are safety glasses, rubber gloves, and back braces. These PPE are only worn in some areas of the facility.
Marshfield Door Systems, Inc. Inspection 303864029
The inspection occurred as a result of a complaint. Workers at the inspected facility are potentially exposed to formaldehyde in the smoke emitted from the electronic press. Air sampling reports from the inspection indicated the use of PPE such as safety glasses and gloves by some workers. Respirators were not worn.
Fiberesin Industries, Inc., Inspection 307061689
The inspection occurred as a result of a complaint. Fibersin Industries manufactures particleboard. Air monitoring during the inspection indicated no overexposure to formaldehyde at the inspected facility. Because no overexposures were found, it is not mandatory for the employer to provide workers with respiratory protection. Eye protection is provided to workers, but the wearing of eye protection is not enforced. PPE for the press operator include the occasional use of gloves and the use of safety glasses and hearing protection.
Unilin Flooring NC, LLC., Inspection No. 312479835
OSHA conducted a partial inspection of the facility as a result of a non-formal complaint. The inspection did not cover all operations at the facility and OSHA did not identify any violation of OSHA standards or regulations. The inspected facility manufactures high density MDF used primarily in flooring material. The company provides respiratory protection training and fit testing for workers in the production area.  Workers were wearing 3M 6300 half masks with formaldehyde cartridges; they also had the option of using full face cartridge respirators and had been fit tested of both types of respirators. The company also conducts periodic formaldehyde sampling and has performed a ventilation study on-site.
2.0	Composite Wood Product Fabrication

Plymart Inc. Inspection No. 308245372
Plymart is a high production cabinet shop with a series of large warehouse size buildings. The cabinets are mainly constructed of particleboard frames with hardwood doors. OSHA conducted a combined safety and health programmed inspection at the facility and cited Plymart for poor ventilation and housekeeping in the spray finish booth. However, air sampling throughout the facility indicated that concentrations of formaldehyde, as well as dust and solvent were all below the PEL and that there was no overexposure. Hence, the company had "decided not to require tight fitting respirators."
Bushline Inc. Inspection No. 306132275
This inspection was a general schedule comprehensive occupational health inspection. Bushline manufactures upholstered furniture. During the OSHA inspection, the facility was cited for poor ventilation in the spray booth, the lack of PPE hazard assessment or employee training certification, lack of impervious gloves and clothing for workers handling corrosive liquids, as well as eye and face protection for employees potentially exposed to hazards from acids or caustic chemicals.
Formaldehyde glue is mixed and applied by hand to glue wood sections together in the rough mill area. The report stated that "proper PPE and an eyewash and shower were not provided in this area" and that formaldehyde sampling results were below the action level.
An employee wore the Cabot Safety half face air purifying respirator while mixing the adhesive in the chair line area, where wooden frame chairs are assembled using pneumatic guns and a formaldehyde glue. Past air sampling indicated that the formaldehyde concentration was below the PEL in this area.
England Inc. Inspection No. 307674051
This inspection was a general schedule comprehensive occupational health inspection. England Inc. manufactures furniture cushions and mattresses. During the inspection, the facility was cited for not providing the proper PPE where there is potential for exposure. The only worker PPE (worn in select areas of the facility) are safety glasses, smock, and hearing protection. It appears that no respirators were worn. The facility uses a water-based non-toxic glue in its processes, and sampling results show formaldehyde exposure below the OSHA PEL.
Harris-Tarkett Inc. Inspection No. 307206987
This inspection was a general schedule comprehensive occupational health inspection. During the inspection, workers were observed to wear a combination of safety glasses, gloves, and hearing protection in the wood processing area, and in the long strip area, where wood products are being sorted, cut, glued, pressed and finished. It appears that no respirator was worn in the areas with potential formaldehyde exposure. Respirators were also not worn by workers in the chemical room of the finishing department where they were exposed to methyl isobutyl ketone above the PEL and STEL levels.
The Commercial Furniture Group. Inspection No. 311144059
This inspection was a general schedule comprehensive occupational health inspection. The Commercial Furniture Group manufactures wooden chairs at the inspected facility. The operation here consists of a rough mill, a frame assembly area, a spray finishing area, a fabric cutting and storage area, and an upholstery area. The inspection report did not indicate the use of formaldehyde-based adhesives although formaldehyde could be emitted from the wood boards used to manufacture chairs. According to the report, workers wear safety glasses and hearing protection in certain areas of the facility. There was no indication for respiratory use. Air sampling results also indicate the formaldehyde concentration was below the OSHA PEL, therefore, the facility would not be required to provide respirators for formaldehyde exposures.
Gunlocke Company, LLC. Inspection No. 307690578
The inspection at Gunlocke Company was conducted as a result of a compliant. During the inspection, the observed workers were not wearing respirators.
Armstrong Cabinets Products. Inspection No. 306021239
This inspection was a planned health inspection. Armstrong Cabinets manufactures bath and kitchen wood cabinets. OSHA cited the company for not providing protective eye and face equipment to prevent chemical splashes. The facility has a written respiratory protection program but the use of a respirator is not mandatory. During the inspection, workers were not wearing respirators or dust masks even though the facility has seven spray booths. Occasional PPE worn include apron and gloves.
Wood Goods Industry Inc. Inspection No. 307041707
The inspection was conducted as a result of a complaint. The inspection summary suggests that this facility produced various wood products, such as tables, from rough lumber. Lumber was rip-sawed, chopped, and glued with non-hazardous wood glue (does not contain formaldehyde). The facility also had a spray operation where three chemical sprays, a water based stain, a vinyl sealer, and a clear top coat were sprayed onto the wood products. Employees rotated between spraying operations and hand sanding, wiping stains, and setting tables on the conveyor tracks. Air sampling for formaldehyde was conducted on an employee spraying the top coat. The other two coatings do not appear to contain formaldehyde.
The facility had an operational spray booth in place but did not require respirator use. During air sampling of spraying activities, only some workers were observed to wear a respirator with organic vapor cartridges.  Other PPE worn by workers during air sampling include nitrile gloves, safety glasses, hard hat, ear plugs, and steel toe shoes.
Parenti & Rafaelli, Ltd. Inspection No. 305228652
The inspection was conducted under the Site Specific Targeting program. A safety inspection had been initiated previously and the health inspection was initiated to address health issues such as spray booths, exposure to wood dust and formaldehyde. The company had no previous history of OSHA inspections.
The company required the use of half face respirators in the spray booth and dust masks are available to the rest of the employees. The company also required employees to wear safety glasses, steel toe shoes, gloves, and respirators in the spray booths.
The company made custom millwork and woodwork for commercial and residential sites. The types of wood used vary depending on customer specification but includes fir, pine, oak, maple, mahogany, cherry and particleboard. Air sampling for formaldehyde was below the PEL.
Benvenuti and Stein, Inc. Inspection No. 312188972
The health inspection was initiated due to a non-formal complaint regarding a chemical spill. The company made custom design wooden cabinets and the facility was divided into cabinet making, cabinet finishing, and the dock. The finish coating used during the spray operation contained formaldehyde.
The company provided a half-face cartridge respirator to reduce employee exposure to formaldehyde but did not implement a written respirator program. Other PPE worn by workers include safety glasses and safety shoes.
Ameriwood Industries Inc. Inspection No. 311606883
OSHA conducted this partial health inspection as follow-up to a previous inspection that was conducted in response to a complaint. OSHA determined that the formaldehyde exposure for workers operating the autodrill was well under the PEL based on personal monitoring. Workers only wore safety glasses and ear plugs during air sampling.
Tru-Wood Cabinets, Inc. Inspection No. 307013250
OSHA conducted this partial health inspection in response to a complaint. Tru-Wood Cabinets, Inc. manufactures wood cabinets (kitchen and bathroom) to be installed on new homes. At the time of inspection, the company employed 279 employees in two working shifts. The company had two buildings: frame door production and spray painting operations were conducted in building #1, while panel cutting and finishing occurred in building #2.
Monitoring data show exposure for formaldehyde was below the OSHA PEL. The only PPE listed in OSHA's air sampling worksheets were safety glasses and ear plugs. The inspection report indicates voluntary use of particulate masks by workers in building #2; however, it was uncertain how frequent these respirators were being worn.
Jimson Manufacturing Co. Inspection No. 303424014
OSHA conducted this partial health inspection in response to a complaint. This company manufactures furniture for retail stores. Sheets of MDF are received at the company (facility) and the wood is cut to size using panel saws.  Foil is applied to edges and flat pieces of wood via heat and pressure; and furniture is assembled with staple guns.
OSHA monitoring indicates that the formaldehyde exposure level was well below the OSHA PEL. The PPE listed in OSHA's air sampling worksheets included prescription glasses and safety glasses (with or without side shields). Dust masks and respirators were not worn.
Newood Display Fixtures Manufacturing Company. Inspection No. 304064835
Newood Display Fixtures Manufacturing is a large store fixture manufacturer with a staff of 60 employees. The health inspection was initiated based on an anonymous complaint alleging exposure to lacquer, paints, and formaldehyde in the west end of the mill. Some of the operations that occur at this facility include spray painting operation, glue-up, and packing. The spray area consists of three spray rooms and a spray painting prep area. The lacquer pump is electrically interconnected to the ventilation system, so that the spray guns will not operate if the ventilation system is inoperable. Sampling results indicated that formaldehyde TWA reached 0.299 and 0.276 ppm; however, the 8-hour TWA were quite low due to the shortness of the sampling period. The inspection did not result in a citation.
The only PPE listed in the air sampling report is 3M-N95-8210. This appears to refer to the N95 disposable particulate respirator model 8210.

Simple Designs Manufacturing Inc. Inspection 306629171
This inspection was a partial health inspection conducted as a result of a complaint. The inspected facility makes furniture using plywood, hardboard, particleboard, and oriented strand board (OSB). The company safety process manual states that safety glasses and ear protection must be worn throughout the mill area. Gloves are also required in some areas of the plant. Dust masks are available for use. Air sampling reports also indicate the occasional use of an apron. However, none of the workers inspected wore a respirator.

Appendix H
SUMMARY OF ADDITIONAL EXPOSURE MONITORING DATA FROM MANUFACTURING

Table H-1. Formaldehyde Exposure Levels for Plywood, Particleboard, and Medium-Density Fiberboard Manufacture
                               Authors/Articles
                                  Publication
                      Air Concentrations of Formaldehyde
                               Study Population
                               (Exposed Workers)
                          Abstract and Salient Points
The Workers' Compensation Board BC (WorkSafeBC)

Discussion Paper  -  Occupational exposure limit for formaldehyde. March 20, 2007
Not Applicable
Plywood manufacturing: predominantly below 0.3 ppm as 8-hour TWA
Pressed/panel particle/fiberboard manufacturing: 0.3 ppm as 8-hour TWA exceeded at times with an exposure range of 0.07 to 5.00 ppm
Workers in a variety of industries in British Columbia including those in the pressed/panel particle/fiberboard manufacturing facilities.
Abstract:
None Available

Salient Points:
* Sampling data collected by WorkSafeBC over a period of 15 years (1990 to 2005) in British Columbia and other locations, including Ontario, Quebec, and the Netherlands indicate that worker exposure to formaldehyde is likely to occur primarily in the forest panel board manufacturing sector (plywood, particle/fiberboard, oriented strand board, laminated wood products manufacturing), resin manufacture, acute care hospitals, university and other laboratories, and funeral homes.

* The exposure data indicate that, overall, exposure levels have decreased over time as control and procedural measures have improved. This is particularly evident when one compares readings taken in the early 1980s with those in the late 1990s.

* The results indicate that industries in which exposure levels were predominantly below the current 0.3 ppm 8-hour TWA exposure limit include:
  oo   Foundries;
  oo   Resin manufacturing; and
  oo   Plywood manufacturing.

* Industries in which the current 0.3 ppm 8-hour TWA exposure limit (for British Columbia) was exceeded include (range of exposure shown):
  oo   Paperboard & cardboard manufacturing (0.04 to 0.38 ppm);
  oo   Laminated wood products manufacturing (0.24 to 0.38 ppm);
  oo   Pressed/panel particle/fiberboard manufacturing (0.07  -  5.00 ppm);
  oo   Oriented strand board manufacturing (0.03 to 0.32 ppm);
  oo   Funeral homes (none detected to 0.74 ppm);
  oo   University laboratories (0.52 to 1.15 ppm);
  oo   Hospitals & medical clinics and laboratories (0.02 to 1.35 ppm); and
  oo   Poultry hatcheries (0.1  -  0.35 ppm).

* Formaldehyde exposure levels in a plywood manufacturing plant in 2002, as reported by the Ontario Ministry of Labour, ranged from 0.16 to 0.17 ppm as 8-hour TWA, with a 15-minute STEL range of 0.14 to 0.29 ppm and instantaneous ceiling limit values ranging from 0.33 to 0.44 ppm.

* Formaldehyde exposure levels in two particleboard manufacturing plants were also reported by the Ontario Ministry of Labour in 2002. The 8-hour TWA levels ranged from 0.07 to 0.20 ppm in one plant and from 0.08 to 0.11 ppm in the other. The range of the 15-minute STELs was from 0.15 to 0.54 ppm and 0.14 to 0.29 ppm, respectively, and for instantaneous ceiling limit values, from 0.18 to 7.47 ppm and 0.17 to 0.50 ppm, respectively.

Table H-2. Formaldehyde Exposure Levels for Plywood Manufacture
                               Authors/Articles
                                  Publication
                      Air concentrations of Formaldehyde
                               Study Population
                               (Exposed Workers)
                          Abstract and Salient Points
Fransman W et al.

Respiratory symptoms and occupational exposures in New Zealand plywood mill workers.

Ann Occup Hyg. 2003 Jun;47(4):287-95.

0.08 ppm to 0.60 ppm (0.01 to 0.74 mg/m[3]) [Geometric mean of this range = 0.06 ppm (0.08 mg/m3 )]
112 plywood mill workers.
Abstract: