Urea-Formaldehyde Foam Insulation: Health Effects and Regulation

UREA-FORMALDEHYDE FOAK INSULATION:

HEALTH EFFECTS AND REGULATION

MINI BRIEF NUMBER MB82228

AUTHOR:

Kichael M.

Simpson

Science Policy Research Division

THE LIBRARY OF CONGRESS

COKGRESSIONAL RESEARCH SERVICE

KAJOR ISSUES SYSTEM

D A T E ORIGINATED 04/27/82

D A T E UPDATED 12/12/83

.

FOR ADDITIONAL I N F O R M A T I O N CALL 287-5700

1215

CRS- 1

I S S U E DEFINITION

.-foam insulation (UFFI), a synthetic substance which when

Urea-formaldehyde

new i s a n excellent thermal insulator, has

been

installed

i n hun,dreds of

thousands of commercial and residential buildings a s a means

of

reducing

heating and cooling costs.

At the present t i m e , however, some residents of

health-related

discomforts;

these buildings a r e complaining of a variety of

research indicates that exposure to UFFI may have serious health effects.

several

foreign governments have

taken

F o u r U.S. Federal agencies and

different actlons in r e l a t ~ o nto controlling potentla1 human

health

effects

resultant from exposure to UFFI;

these a c t i o n s range

from use

bans and

compensation programs to refusal t o r.egulate i n the absence of

evidence of

significant risk to humans.

Public policymakers' concerns currently f o c u s on

compensatory relief programs and congressional reviews of UFFI

regulations

and regulators.

BACKGROUKD

General Information

Rising energy p r i c e s , shortages of other insulating materials, and the l o w

cost a n d ease of installation of UFFI encouraged a dramatic increase i n the

second half of the 1 9 7 0 s in the number of buildings insulated with

UF

foam.

As a way to reduce energy consumption and dependence upon

foreign

suppliers

of e n e r g y , the U.S. Government extended thousands of tax credits to encourage

the insulation of buildings; UFFI

qualified a s a tax creditable way

to

i n s u l a t e a building.

(Please see MB83210 -- T h e Residential Energy

Tax

Credits; a l s o , IP0033 -- Energy Conservation.)

Building codes i n the United States rate UFFI a s a

combustible material;

of

as a

result, when

installed

inside buildings, a thermal barrier

fire-resistant material was requires.

Installation involved mixing

and

injecting under pressure, behind the thermal barrier, partially

polymerized

UF r e s i n with a f o a m i n g agent and a n acid cat-alyst.

The foam hardened

in

minutes and cured within days.

But a number of factors in this process could

a l l o w excessive formaldehyde gas

from the UFFI t o be

emitted

into the

building:

excessive formaldehyde in the initial resin solution,

excessive acid catalyst in the foaming a g e n t ,

excessive foaming a g e n t ,

installation i n high heat o r humidity,

installation with chemicals a t sub-optimal temperatures,

improper use of :vapor barriers, and

installation in ceilings or other improper places.

Even when properly installed, UFFI will emit

formaldehyde in decreasing'

quantities over time (one monitoring study found

1 0 to 1 0 0 times greater

emission levels with newly installed UFFI relative to UFFI installed 3 to 5

years before measurement):'

And UFFI tends to shrink with a g e , reducing

its

value a s a thermal insulator.

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MB82228

UPDATE-12/12/83

While formaldehyde gas i n measurable amounts has been

detected

i n homes

with

U F F I , gaseous formaldehyde can

also

be

emitted

by

plywood,

particleboard, carpeting, draperies, gas

stoves, tobacco

smoke,

Paper

products

such a s grocery bags and

tissues,

wrinkle-resistant

and/or

water-repellent-materials and clothing, and other products held

together by

UF resins.

Health Effects

Several studies using y o u n g , healthy adults exposed f o r short durations 'in

Clean and controlled atmospheres to formaldehyde gas i n concentrations a s

smail as 0.2 parts per million (ppm) have shown irritant effects of the

eye,

n o s e , and throat.

Many

occupational

and

residential

studies have

shown

formaldehyde g a s levels of 0.03 to 4.15 ppm t o be associated with e y e , n o s e ,

a'nd throat irritation, nausea, vomiting, diarrhea, h e a d a c h e s , irritability,

and skin rashes.

The Committee o n Toxicology

of the National

Academy

of

Sciences has reported that i t found no population

threshold

for the acute

effects of formaldehyde gas.

Studies indicate that formaldehyde

can react readily with other chemicals i n humans a n d animals;

i s mutagenic i n bacteria, viruses, f u n g i , insects, a n d mouse

lymphoma cells with o r without metabolic activitation;

induces chromosomal recombination i n y e a s t , i n s e c t s , cultured

mammalian cells and rats;

induces cellular transformation in certain mouse cells;

induces cancer in rat nasal tissue; and

may be carcinogenic in other species and other tissues.

(For further information on health

effects of i n d o o r a i r , please

see

IB83074 - - Indoor Air Quality and Health

Impacts of

Energy

Conservation:

Some Congressional Options.)

CONSUMER PRODUCT SAFETY COMMISSION

Consumer

Product Safety

Commission

(CPSC)

On Mar. 2 , 1 9 8 2 , the U.S.

UFFI

in non-mobile

proposed a regulation to ban the future installation of

residences a n d

schools.

T h e proposed

regulation

was

based

upon

the

unreasonable risks to consumers

from the irritation, sensitization, and

possible carcinogenic effects of formaldehyde potentially

emitted by

UFFI,

the availability

of alternative insulating materials

for

nearly . a l l

app,lications, and the lack of alternative a.pproaches to eliminate

or

adequately reduce the risks.

The proposed ban was thus deemed necessary

and

i n the public interest.

It was not to apply t o mobile h o m e s (see "Department

of Housing and Urban Developmentw hereafter)

nor t o 'offices, w a r e h o u s e s ,

stores, or similar commercial buildings (see "Occupational Safety a n d Health

Administration" hereafter).

It was a l s o t o have no e f f e c t upon UFFI

already

for granting

installed in buildings.

T h e proposal

included a provision

exemptions to any company which could demonstrate that i t could consistently

manufacture a UFFI product which

does not pose a n

unreasonable

risk

to

consumers.

T h e CPSC published the regulation in the F e d e r a l Register (47 FR

14366) o n Apr. 2 , 1982. Following 1 0 days of judicial r e v i e w , the regulation

was sent on f o r congressional review. Congress had 90 d a y s in which to veto

or otherwise modify the rule.

CPSC' planned to enforce t h e regulation, using

CPSC

t h e authority in sections 19 t o 2 1 of the Consumer P r o d u c t Safety Act.

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MB82228

UPDATE-12/12/63

plans t o react to consumer complaints of il'legal installations by

inspecting

UF manufacturers' and UFFI i n s t a l l e r s 1 sales r e c o r d s , then assigning civil o r

criminal penalties against violators.

By Apr.

2 3 , 1 9 8 2 , court cases i n

several jurisdictions haa been f i l e d , challenging the validity of the b a n ,

its w o r d i n g , its propos'ed effective date, and its inapplicability to

Commercial building installations. Despite t h e s e , the ban became effective

o n Aug. 1 0 , 1982.

(The ban was lifted on Aug. 2 4 , 1983).

Under provisions

of the ban, any installer of formaldehyde-emitting

UFFI was subject to a

civil fine ranging f r o m $ 2 , 0 0 0 to $ 5 0 0 , 0 0 0 per installation.

Any installer

knowingly and willfully continuing to install UFFI after being notified by

the CPSC that he was in noncompliance with the l a w was t o be

subject to

criminal penalties of up to one year in jail and/or fines up to $50,000.

CPSC found that approximately

5 0 0 , 0 0 0 non-mobile

homes in the United

States are presently insulated with U F F I , or 0.59% of the total number of

non-mobile homes i n the United States today. Approximately l , 7 5 O r 0 0 0 people

presently

reside in UFF-insulated

homes.

This i s 0.80%

of the U.S.

population.

On' average t h e n , 3.5

persons l i v e in each UFF-insulated

non-mobile home.

As of 1 9 8 0 , the CPSC received from residents of UFF-insulate6

homes one

complaint of physical effects for every 200 installations -- the physical

health-effects complaint rate was 0.5%.

T o d a y , with

5 0 0 , 0 0 0 installatioLs,

assuming the health-effects complaint r a t e is unchanged, there could be 2 , 5 0 0

UFFI-installation complaints.

And with 3.5 persons per installation, this

means there could be 8 , 7 5 0 persons nationwide potentially being

exposed to

UFFI i n their homes t o the point of complaining t o the CPSC.

And

the C P S C

has not been alone i n handling UFFI-related complaints..

A university-based

environmental health department in the Pacific Northwest monitored 244 homes

a n d found 4 0 9 residents

(158 adult males, 1 2 2 adult f e m a l e s , and 1 3 9

children) exhibiting a t least one symptom of formaldehyde exposure. T h e same

department handled 2 0 8 0 telephone complaints in the past year.

These data

suggest that CPSC may have underestimated the number of people exposed to

formaldehyde a t a . l e v e l sufficient to evoke a complaint.

According t o CPSC, the average cost of a UFFI installation w a s $1,500.

The average cost of removing the UFFI i s from $6,000 to $20,000.

This may

include replacement of the UFFI with another type of insulation depending o n

the preferences of the consumer a s to who performs the service.

Nationally,

the cost of UFFI removal could cost a s much a s $3-10 billion.

The effect of UFFI in residential walls on non-mobile home r e s a l e value i s

inconsistent:

the resale value may be increased

(due to improved thermal

insulative properties), may be reduced

(due to negative value of UFFI

publicity a n d potential health effects), or may be unchanged.

T h e Commission

has estimated the possible property value reductions a t $ 6 , 0 0 0 t o $ 2 0 , 0 0 0 per

h o u s e , i.e., the c o s t of removal of the UFFI.

T h e r e does n o t ' n o w appear to

b e ' s o l i d evidence from which to assess the consistent direction o r magnitude

of effect upon house prices due to UFFI.

There a r e currently n o national

laws requiring sellers to disclose whether their houses have UFFI.

But the

National Association.of Realtors h a s issued a directive to all realtor boards

nationwide suggesting that: (a) the seller Complete a form stating the " Y e s , "

" N o t 1 'or "Maybe" presence of UFFI, a n d ; (b) the purcha.ser complete a second

form acknowledging receipt of this information prior to tendering a n offer to

buy.

Of crucial le.gal concern a r e the adherence t o the real estate agents'

C o d e of Ethics, and the implied warranty of habitability

(wherein an a g e n t

must disclose information of any known health hazard).

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T h e CPSC stated that complaints of health effects from UFFI exposure occur

With installations of any a g e , from recent to several years p r i o r ; 1 9 7 7 w a s a

notable year for the dramatic increase in the number of UFFI installations.

residential UFFI installations:

C P S C estimates the following number

YEAR

197 5

1976

1977

1 978

1 979

1980

1961

CPSC-ESTIMATED XUMBER

OF RESIDENTIAL INSTALLATIONS

30,000

20,000

-

W h i l e the number of installations has been steadily d e c l i n i n g , the

Of health-effects complaints has been proportionately increasing.

number

concentrations found

T h e CPSC also stated its position that formaldehyde

c a u s e . harmful

health effects.

in homes are sufficient, in i t s opin i o n , to

T h e Commission's upper value of risk was estimated to be 89 malignant cancers

1 , 7 5 0 , 0 0 0 persons

currently

developing amcng the estimated

popu lation of

exposed i n 5 0 0 , 0 0 0 UFFI homes, using the data from actual measurements

in

residences. The 89 cancers repre sent 0.005%

of

the 1 , 7 5 0 , 0 0 0 persons

currently exposed

t o UFFI

in th eir h o m e s , and

0.00004%

of

the U.S.

of

avoiding one UFFI-caused

population.

The CPSC estimates the cost

malignant cancer t o be $164,000 t o $ 292,000. T h e Commission pointed out that

these ratios considered only the red.uced risk of malignant

c a n c e r , and

did

not include other health benefits, r,educed medical and

related

c o s t s , and

benign tumors.

Under

certain. condi tions, certain

States

will

take

formaldehyde

asurem ents in homes on request.

Using

the National

Institute

for

a n d Health

cupati onal Safety

(NIOSH) procedure are

Iowa,

Kentucky,

s s a c h u setrs, Michigan, Minnesota, New H a m p s h i r e , New J e r s e y , New

York,

U sing the Drager system a r e Connecticut and Texas.

i o , a n d' Washington.

e t w o procedures

a r e chemically

slightly different but

yield

similar

suits with comparable accuracy; some scientists maintain

that the Drager

system is less reliable.

Formaldehyde can be filtered o u t of the a i r , extracted o n t o a chemically

treated wick-bottle or g e l , sealed

in the w a l l s , or vented.

Costs and

effectiveness of these methods were not presented in the C P S C regulation (see

"The Canadian S i t u a t i o n v hereafter)

.

On Jan. 1 2 , 1 9 8 3 , the CPSC announced that i t i s collecting information o n

formaldehyde released from pressed-wood products.

One possible

result of

this investigation could be a product standard requiring

that pressed-wood

products emit no m o r e than a

specified a m o u n t of

formaldehyde.

Such a

standard may be met through carefully controlled and monitored

manufacturing

and curing techniques.

(The CPSC concluded that such a standard could not be

met b.y UFFI owing t o the excessive number and magnitude

of

uncontrollable

variables involved i n the installation a n d

curing of UFFI.)

A ban on

pressed-wood products i s another possible, but less l i k e l y , outcome of

the

CPSC

investigation.

The ,CPSC investigation

w a s prqmpted

by

consumer

complaints involving 3 7 0 0 people.

In August 1 9 8 2 , the C o n s u m e r s Federation

CRS- 5

of America

requesteC the CPSC to limit

formaldehyde

emissions

from

pressed-wood products to 0.05 ppm.

The CPSC plans to make

a n announcement

about the findings of its investigation in the third quarter of FY.83.

the 5th Circuit Court in New

On Apr. 8, 1 9 8 3 , a three-judge panel of

Orleans ruled rhat the CPSC ban of UFFI i s illegal; the decision was based

upon their finding that the Commission did not present sufficient evidence to

support the ban action.

On May 5 , 1 9 8 3 , the CPSC filed for a rehearing.

On Apr. 2 0 , 1 9 8 3 , 23 Members of Congress sent a letter

t o CPSC Chairman

Nancy Steorts stating that "Formaldehyde insulation is a dangerous

substance

that must be kept out of homes."

The letter,urged the chairman to "Please do

all you can to prevent this ban from being lifted."

The Insulation Contractors Association of America's Executive Director, R.

Hartly E d e s , commented on the Fifth Circuit court's decision by

saying

"I

d o n ' t see that there's going to be any new effect on the industry by i t s (the

CPSC ban on future UFFI installations) being overturned."

Edes added

that

members of

the association

"questioned

(UFFI's) efficacy

a s insulating

material because of i t s shrinkage (after installation).

When you leave up to

a 4% void in insulation, you can have heat loss of up to 50%."

Ed Stana of the Formaldehyde Institute commented that t h e UFFI

" i s down to just about z e r o , " but that " i t ' s too early to tell" if

Orleans ruling would likely revive the business.

industry

the New

paper

ranking 1 7 known

On May 9 , CPSC released a draft discussion

carcinogens.

Formaldehyde was the seventh most potent carcinogen.

T h e paper

discussed the major disadvantages and

limitations of potency

comparisons,

including nonconsideration of human exposure information, a n d reduction of

risk assessment ranges to single values.

T h e paper i s receiving peer review.

By mid-June 1 9 8 3 , the CPSC petition f o r a re-hearing had been denied.

In

a letter dated Aug. 2 4 , 1 9 8 3 , the Solicitor General notified the CPSC that he

would not issue a writ of certiorari to send the case to the

Also, the ban was lifted o n that date.

Supreme

Court.

DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT

The U.S. Department of Housing and Urban Development (HUD) has prohibited

the installation of rigid formaldehyde insulation in mobile homes since 1 9 7 6

(based upon common knowledge of -the fire h a z a r d ' o f the insulation), and i t is

currently considering whether a rule i s needed to regulate formaldehyde in

particleboard, draperie's, carpeting, and other products in mobile homes (Aug.

2 8 , 1981 Federal Register).

On Mar. 2 2 , 1 9 8 3 , HUD disapproved further use

of UFFI

i n its mortgage

insurance and low-income Public Housing program pursuant to the C P S C ban.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

In 29 CFR 1910.1000 Table 2-2, the Federal. Occupational Safety and Health .

Administration (OSHA) states that employees ma.y be exposed to formaldehyde a t

a level of 3 ppm a s a n 8-hour time-weighted average (this i s the Permissible

CRS- 6

Exposure L i m i t , or PEL), with an acceptable ceiling concentration of 5 p p m ,

and that the acceptable maximum peak above

the

acceptable

ceiling

Concentration for a n 8-hour shift is 1 0 ppm f o r less than 3 0 minutes; this

applies

only to States ad~ninistered by Federal OSHA.

State-administered

- programs have a PEL of 2 ppm.

Some labor unions have petitioned OS HA t o reduce its

concentration , and the National Institu t e o f occupa tiona

(the research arm of- OSHA) has proposed the P E L be reduc

has responded that i t does not recogniz e su f f icient evi

a n empl oyee

tightening of the standard.

Current1 Yr

complaint and an CSHA inspector can res pone. by equi PPing

personal dosi meter to measure the worke r ' s exposure to

has received reports of rare nasal c a,ricers i n

w

f o r m a l d e h y d e ; these reports are being investigated.

allowable expo sure

Safety and H e alth

d to 1 p p m , but OSHA

ence to warran t a

can f i l e a he alth

the employee wit h a

formaldehyde.

OSHA

rkers

exposed

to

ENVIRONMENTAL PROTECTION AGEHCY

Environmental

On Feb. 1 2 , 1 9 6 2 , J o h n A. Todhunter -- then the U.S.

Protection Agency's (EPA) assistant administrator for pesticides and toxic

substances -- announced

the agency's official position on f o r m a l d e h y d e ,

Saying that the chemical should not be regulated under section 4(f)

of the

T o x i c S u b s t a n c e s ' C o n t r o l Act because it does not cause "significant risks of

serious o r widespread harm of cancer," and that the E P A W s tentative decisions

in 1 9 8 0 to regulate formaldehyde were "incomplete a n d flawed."

Despite the

a g e n c y ' s conclusion not t o regulate formaldehyde under section 4(f) of T S C A ,

the EPA continued in i t s 5-step workplan f o r evaluating formaldehyde.

The

workplan schedule began Jan. 4, 1 9 8 2 , and w a s planned to take 8 months to

complete. T h e first step was almost complete a s of Feb. 1 2 , 1982.

The

entire study was to include evaluations of the applicability of animal data

to potential human carcinogenicity, human exposure levels and resultant

r i s k s , coordinated interagency and outside group data-gathering, a n d outside

3 0 , 1 9 8 2 , EPA

peer review of hazard, exposure, and risk data.

On Apr.

Pesticides and Toxics Assessment Division Director Joseph Merenda said that a

major revision of the schedule was to be announced when ready; a date w a s not

given a t that time.

On May 1 8 - 1 9 , 1 9 8 2 , the House Subcommittee on Commerce, Consumer and

Monetary Affairs of the House Government Operations Committee held hearings

on the effects of exposure to formaldehyde, with emphasis o n formaldehyde

e m i s s l o n ~ from UFFI.

On May

2 0 , 1 9 8 2 , the

House

Subcommittee

on

Investigations and Oversight of the House Committee on Science and Technology

. held a hearing on the specific

topic of E P A ' s posit-ion t o not regulate

formaldehyde under section 4(f) of T S C A , and on the more general topic of

EPA's current position on the level of risk and scientific certainty

necessary t o trigger regulatory action.

In connection with these hearings,

the EPA announced its negotiation wlth the National Center for Toxicological

Research (NCTR) for f u r t h e r formaldehyde research using project-specific

f u n d s from E P A ; the EPA signed the agreement i n July 1982.

EPA said NCTR

will :

Establish expert review panels in the areas

of formaldehyde, toxicology, epidemiology,

exposure, and risk.

CRS- 7

FIB82228

UPDATE-12/12/83

Establish a clearinghouse to identify ongoing

studies and to coordinate the exchange of

scientific data on formaldehyde exposure and

health effects studies.

Develop coordinated data bases of reviewed a n d

validated scientific knowledge in the areas of

each of the panels listed a b o v e , to be

supplemented by new data a s they are developed

through various ongoing studies.

Hold an international consensus building

workshop in which the panels and other

scientists krill discuss' the available d a t a ,

reach conclusions as to their interpretation,

a n d identify an.y remainins gaps requiring

further research.

Complete and submit for publication a

peer-reviewed report of the workshop's

conclusions concerning formaldehyde health

risks.

EPA said the NCTR p.rogram will

be

"supplemented by

a

limited numSer

of

additional Office of Toxic Substances projects

aimed a t

supporting

the

efforts of the expert revi.ew pan'els o r a t filling certain data gaps;

the

specific nature of those activities will

be defined

as

the panels

are

established a n d begin reviewing the available data bases."

EPA a t that time

did n o t say if discussions to be held in connection

with

the NCTR

project

would be open to the public or other scientists.

Coordinating

the EPA-NCTR

project i s a n Executive

Panel

composed

of

2 representatives each from

ineustry, a c a d e m e , government, and public interest groups.

The f i r s t meeting

of the P a n e l was held on Oct. 29-30, 1 9 8 2 ; discussion

topics included

the

desirability and.workability of opening meetings to the public.

The Panel

concluded that pubiic input is needed and will be sought v i a announcements in

the Federal Register (the first of which

appeared Dec.

7 , 1982), and

in

relevant journals (one advertisement appeared in the Dec. 1 7 , 1 9 8 2 , issue of

Science magazine).

The P a n e l a l s o planned

to hold

consensus w o r k s h o p s ,

focusing entirely upon the scientific (and not the policy) issues relating to

formaldehyde from approximately J u n e through October 1983.

On Jan. 7 , 1 9 8 3 , the Natural Resources Defense council

(NRDC) sent a

letter to the EPA Administrator (then Anne. Gorsuch

Burford)

notifying

the

Agency that the NRDC intends t o

sue the government for failing to list

formaldehyde under section 4(f) of TSCA; the suit will be

filed after

the

required 60-day period following receipt of the notification letter.

On July 1 2 , 1983 President Reagan s i g n e d - t h e HUD and Independent Agencies

task

Appropriations Act of 1 9 8 4 which included $ 2 million f o r a multi-agency

force on indoor air quality; the task force is co-chaired by the E P A , C P S C ,

and the Department of Energy.

T H E CANADIAN SITUATION

The u s e of UFFI in residences was banned i n Canada i n December

1980, as

the r e s u l t of tremendous public pressure in response to media coverage o f the

CRS- 8

potential health effects of UFFI.

T h e Canadian

Corporation

(CMHC) instituted a response program

modification over time.

Mortgage and Housing

which has

undergone

The first step of the program was an information campaign, to

citizenry of t h e UFFI response pr6gram.

notify

the

Originally, homeowners had

to demonstrate that they had ex,perienced

medical problems due to UF$I and/or had homes with indoor formaldehyde levels

exceeding 0.1 ppm i n order to be eligible under the UFFI response program.

T h e h o m e o w n e r s . h a d to perform preliminary testing to determine if full-scale

testing was required. Full-scale testing c o s t $ 1 0 0 , reimSursed through the

Now, preliminary testing is optional and full-scale t e s t i n g , if

program.

r e q u i r e d , i s free.

F u r t h e r , homeowners originally had to imple'ment corrective m.easures

recommended by CMHC to be eligible for financial assistance. N o w , the kind

of Corrective measures undertaken is the choice of the homeowner, with CMHC

providing technical information and estimates for a l l possible

corrective

measures, and a current list of registered contractors who have successfully

followed the government training course o n corrective measures.

Homeowners originally had to pay $100 to attend a training course on

corrective m e a s u r e s , With no choice of location of study. N o w , the course is

f r e e , is available in more a r e a s more often (including evening and weekend

courses), and even includes a home study program. This i s the s a m e training

course required of registered contractors.

Upon successful completion of the

c o u r s e , a homeowner may perform his own corrective measures and be eligible

for assistance through the UFFI program.

Topics c o v e r e d , i n the course

include the relati.ve advantages a n C disadvantages of different remedial

measures in different circumstances; the remedial measures are:

caulking

compounds and vapor barriers; ventilation;

chemical absorption filters;

ammonia gas; r e m o v a l ; a n d - t r e a t m e n t of contaminated material remaining after

removal and p r i o r ' t o rebuilding.

Advance payments up to $ 2 , 5 0 0 are presently available if needed to

Undertake corrective work.

U p to $ 5 , 0 0 0 per dwelling will be given,

tax-free, to registered.homeowners for expenses incurred i n the course of

of 3 dwellings

corrective measures, including removal. T h e r e i s a maximum

per homeowner.

Eligible houses must be located in C a n a d a , a n d may be

detached, l i n k , semi-detached o r part of a r o w , duplex or t r i p l e x , or

prefab,ricated, or a condominium, or a mobile home on a permanent foundation.

Homeowner.s must apply f o r assistance

corrective work can begin later.

by

Sept.

30,

1983,

although

T h e CMHC will test for formaldehyde levels after corrective measures are

completed, a n d a Statement of T e s t Results will be issued to the homeowner.

A s of June 1 , 1 9 8 3 , more than 4 3 , 0 0 0 homeowners were registered

Program.

with

the

In the autumn of 1 9 8 1 the C M H C tested 2 , 4 0 0 homes for formaldehyde levels;

2,000 of those h o m e s had U F F I , and 4 0 0 lacked UFFI.

Of the 400 without U F F I ,

1 1 (around 3%) had formaldehyde levels exceeding 0.1 p p m , t h e highest level

deemed acceptable f o r homes by Health & Welfare Canada. Of t,he 2,000 with

From these d a t a ,

U F F I , 198 (9.9%) had levels exceeding the 0.1 ppm standard.

the CMHC estimated that about 8 , 0 0 0 houses (10% of the housing

stock) in

CRS- 9

MB82228

UPDATE-12/12/83

Canada will require some remedial work.

Canada i s presently spending about $ 1 million for medical

research into

UFFI health effects, a n d . f o r further research

on U F F I , its reaction with

other materials, the characteristics of gases and particles

associated with

U F F I , corrective measures t o reduce or eliminate effects of UFFI

in living

spaces, and testing methods for formaldehyde and other potential emissions.

There i s a l s o the- Canadian Home

Insulation Program

(CHIP) intended

to

assist homeowners t o improve the insulation of

their homes.

A

special

retroactive CHIP grant has been made available to homeowners whose

eligible

costs under the UFFI program exceed $5,000. The program may reimburse 6 0 % of

eligible costs of re-insulation, up to a maximum of:

$500 for a

detached,

semi-detached, r o w , or mobile home; $ 2 8 5 for a unit i n an apartment building

of three stories or l e s s , and of six units or less (includes duplexies); $215

for a unit i n an apartment building of three stories or l e s s , having

more

than six units

(these a r e not

eligible for assistance under

the UFFI

program).

THE INTERNATIONAL SITUATION

Australia

Approximately 4 5 , 0 0 0 structures i n Australia have been insulated with UFFI

since 1971.

Some adverse health effects have been reported where

the foam

Considered

minimal.

was not properly installed; these health

effects were

The concentration of formaldehyde deemed acceptable in private housing i s 0.1

ppm.

Austria

UFFI was f i r s t marketed in Austria about fifteen years ago but

i s seldom

used today i n either the industrial or the private sector.

Where i t i s u s e d ,

owing to

slow construction, possible health problems from

formaldehyde

emissions a r e minimized because most residential buildings are n o t occupied

until a year after the insulation has been installed.

Belsium

sectors.

Common use of UFFI b e g a n . i n 1975 i n the industrial and private

UFFI i s used only t o insulate conventional

buildings

with

hollow w a l l s ,

although tests are i n progress examining

prefabricated

structures.

There

have been reports i n Belgium of medical problems

attributed to UFFI.

The

Belgian government has not yet decided whether

to ban 'UFFI or t o impose

standards a n d controls.

Denmark

UFFI has been used i n Denmark since the early 1950s.

It has been used

in

very reduced quantit7ies s i n c e 1981.

From 1 9 7 6 to 1 9 8 1 , between

1,300 .and

1 , 8 0 0 residences and commercial buildings were insulated each y e a r With UFFI.

About 1 0 0 buildings a year a r e currently insulated with

UF

foam.

Medical

problems have been reported.

Some homeowners

have removed t h e UFFI

from

their homes.

The Danish

government . i s currently preparing

rules and

regulations regarding U F F I , specifying that the concentration of formaldehyde

in room air must not exceed 0.12 ppm.

Finland

Although available for the last ten y e a r s , UFFI has seen only limited

use

i n Finland.

Only old houses built of wood

and a f e w schools have been

Prance

~

appears to have

Though i n common use i n France since the 1 9 7 0 ~ UFFI

caused few complaints.

The installation of UFFI in houses

is regulated by

.the "Centre scientifique et technique

des batiments";

performance of

the

insulation

has been

reported a s

satisfactory when

t h e guidelines a r e

followed.

Germany

later

in the private

UFFI was first used i n industry i n the 1950s and

sector.

There i s a government standard f o r emission l e v e l s and the standard

is Well enforced, although it is reported that the installers have a great

deal of difficulty in meeting the emission standard.

T h e public a p p e a r s

to

have been. informed of

the problems

with

UFFI

emissions.

T h e German

government is drafting UFFI product and installation standards

(Canada did

the same i n 1978).

The Netherlands

The Netherlands has a n acceptable formaldehyde concentration

standard

of

0.1 ppm.

T h e government will test any house claimed t o exceed the standard.

If the air inside the house exceeds the s t a n d a r d , the UFFI

installers are

required to remove the insulation a t their own expense.

UFFI has been widely

installed i n the Netherlands.

There has been very little basic research o n

UFFI conducted by government researchers; they are enthusiastic a b o u t f o r m i n g

a cooperative research program with Canada.

In the Netherlands, formaldehyde

emissions from particleboard receive much

more

attention

than those

from

UFFI.

Norway

hardly

UFFI was first marketed in Norway i n the 1 9 6 0 s yet has

since 1975 because of i t s ineffectiveness a s a thermal insulator.

been

used

Sweden

UFFI was first used o n a limited basis i n the 1 9 5 0 s i n Sweden but w a s

banned i n s o m e regions i n 1 9 7 4 because of i t s strong odor and the damage that

i t can cause to construction materials.

T h e use of UFFI i s presently subject

to very

strict standards.

The

recommended

formaldehyde

level

in

of

UFF-insulated housing ranges from 0.1 to 0 . 7 ppm depending upon the type

building.

United Kingdom

While UFFI wds introduced twenty years a g o to the United K i n g d o m , wider

use of the product has occurred only i n the last ten years.

biore than a

million homes are

currently

UFF-insulated.

few complaints have been

reported in recent years concerning formaldehyde emissions from UFFI.

It is

recommended that UFFI be installed only i n masonry

buildings

in accordance

with established standards.

I t a l y , J a p a n , S p a i n , Switzerland

UFFI has been in limited use in these countries for about

fifteen years.

. ~ h e s ecountries appear to have no restrictions on the installation of

UFFI,

and f e w significant problems resulting from it.

It should be noted that the

UFFI used in Spain and

Switzerland a r e improved

products,

though

still

capable of emitting formaldehyde.

P O I N T S FOR FURTHER CONSIDERATION

of need

Public policymakers' concerns currently f o c u s on 1) the question

for and the mechanics i n establishing Federal programs

to compensate those

persons suffering adverse health effects from exposure t o UFFI

in their

homes; 2) the question of need for and the mechanics in establishing

Federal

programs to

compensate those home'owners whose property

values may

be

adversely affected by having UFFI; and

3)

legislative oversight of

those

Federal agencies whose

responsibilities include the a s s e s s i n g of

risk,

setting of standards, and enforcement of regulations relating to UFFI.

It is

presently a matter of controversy a s to whether

the actions

taken by

the

various Federal agencies are premature, inadequate, unnecessarily restrictive

or intrusive, or scientifically defensible.

H.R. 3819 i n the 98th Congress

seeks to assist homeowners in taking

Corrective measures to reduce the indoor

concentration of

formaldehyde in

dwellings with UFFI exceeding 0.1 ppm by authorizing the Secretary of Housing

a n d Urban Develop,ment t o grant up to $ 1 0 , 0 0 0 per dwelling t o homeowners, for

n o more than three dwellings, for corrective measures taken.

T h e bill

has

been referred to the House Committee on B a n k i n g , Finance a n d Urban Affair-.

H.R. 2533 in the 98th Congress seeks to amend the Internal Revenue Code to

a l l o w a refundable income tax

credit

to individuals f o r expenditures to'

r e m o v e UFFI

from their homes.

The bill a l s o provides

for

testing

formaldehyde levels in h o m e s , and surveying the extent of UFFI

in public

schools.

The bill has been referred to the House Committee o n Banking,

Finance and Urban Affairs, and to the House Committee on Ways and Means.

T h e House Small Business Committee in the 97th Congress held

hearings

on

H.R. 6 3 8 9 , 6 3 9 0 , 6 3 9 1 , 6 4 3 7 and 6 5 2 4 and

the topic of UFFI on Aug. 4, 1982.

S. 2763 Were

bills

i n the 97th Congress aimed a t providing

financial

assistance t o homeowners for removal of the UFFI.