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. CRS- 2 While formaldehyde gas i n measurable with U F F I , gaseous formaldehyde can particleboard, carpeting, draperies, products such a s grocery bags and water-repellent-materials and clothing, UF resins. MB82228 UPDATE-12/12/83 amounts has been detected i n homes also be emitted by plywood, gas stoves, tobacco smoke, Paper tissues, wrinkle-resistant and/or and other products held together by 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. CRS- 3 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). CRS- 4 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.