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REVIEW OF THE ENVIRONMENTAL PROTECTION
AGENCY’S DRAFT IRIS ASSESSMENT OF
FORMALDEHYDE
Committee to Review EPA’s Draft IRIS Assessment of Formaldehyde
Board on Environmental Studies and Toxicology
Division on Earth and Life Studies
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This project was supported by Contract EP-C-09-003 between the National Academy of
Sciences and U.S. Environmental Protection Agency. Any opinions, findings, conclu-
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COMMITTEE TO REVIEW EPA’S DRAFT IRIS ASSESSMENT OF
FORMALDEHYDE
Members
JONATHAN M. SAMET (Chair), University of Southern California, Los Angeles
ANDREW F. OLSHAN (Vice-Chair), University of North Carolina at Chapel Hill
JOHN BAILER, Miami University, Oxford, OH
SANDRA J.S. BAIRD, Massachusetts Department of Environmental Protection,
Boston
HARVEY CHECKOWAY, University of Washington School of Public Health
and Community Medicine, Seattle
RICHARD A. CORLEY, Pacific Northwest National Laboratory, Richland, WA
DAVID C. DORMAN, North Carolina State University, Raleigh
CHARLES H. HOBBS, Lovelace Respiratory Research Institute,
Albuquerque, NM
MICHAEL D. LAIOSA, University of Wisconsin, Milwaukee
IVAN RUSYN, University of North Carolina at Chapel Hill
MARY ALICE SMITH, University of Georgia, Athens
LESLIE T. STAYNER, University of Illinois, Chicago
HELEN H. SUH, National Opinion Research Center, University of Chicago, IL
YILIANG ZHU, University of South Florida, Tampa
PATRICK A. ZWEIDLER-MCKAY, The University of Texas M. D. Anderson
Cancer Center, Houston
Staff
ELLEN K. MANTUS, Project Director
HEIDI MURRAY-SMITH, Program Officer
KERI SCHAFFER, Research Associate
NORMAN GROSSBLATT, Senior Editor
MIRSADA KARALIC-LONCAREVIC, Manager, Technical Information Center
RADIAH ROSE, Manager, Editorial Projects
PANOLA GOLSON, Program Associate
Sponsor
U.S. ENVIRONMENTAL PROTECTION AGENCY
v
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BOARD ON ENVIRONMENTAL STUDIES AND TOXICOLOGY1
Members
ROGENE F. HENDERSON (Chair), Lovelace Respiratory Research Institute,
Albuquerque, NM
PRAVEEN AMAR, Northeast States for Coordinated Air Use Management, Boston, MA
TINA BAHADORI, American Chemistry Council, Washington, DC
MICHAEL J. BRADLEY, M.J. Bradley & Associates, Concord, MA
DALLAS BURTRAW, Resources for the Future, Washington, DC
JAMES S. BUS, Dow Chemical Company, Midland, MI
JONATHAN Z. CANNON, University of Virginia, Charlottesville
GAIL CHARNLEY, HealthRisk Strategies, Washington, DC
FRANK W. DAVIS, University of California, Santa Barbara
RICHARD A. DENISON, Environmental Defense Fund, Washington, DC
H. CHRISTOPHER FREY, North Carolina State University, Raleigh
J. PAUL GILMAN, Covanta Energy Corporation, Fairfield, NJ
RICHARD M. GOLD, Holland & Knight, LLP, Washington, DC
LYNN R. GOLDMAN, George Washington University, Washington, DC
LINDA E. GREER, Natural Resources Defense Council, Washington, DC
WILLIAM E. HALPERIN, University of Medicine and Dentistry of New Jersey, Newark
PHILIP K. HOPKE, Clarkson University, Potsdam, NY
HOWARD HU, University of Michigan, Ann Arbor
ROGER E. KASPERSON, Clark University, Worcester, MA
THOMAS E. MCKONE, University of California, Berkeley
TERRY L. MEDLEY, E.I. du Pont de Nemours & Company, Wilmington, DE
JANA MILFORD, University of Colorado at Boulder, Boulder
FRANK O’DONNELL, Clean Air Watch, Washington, DC
RICHARD L. POIROT, Vermont Department of Environmental Conservation, Waterbury
DANNY D. REIBLE, University of Texas, Austin
ROBERT F. SAWYER, University of California, Berkeley
KATHRYN G. SESSIONS, Health and Environmental Funders Network, Bethesda, MD
JOYCE S. TSUJI, Exponent Environmental Group, Bellevue, WA
MARK J. UTELL, University of Rochester Medical Center, Rochester, NY
Senior Staff
JAMES J. REISA, Director
DAVID J. POLICANSKY, Scholar
RAYMOND A. WASSEL, Senior Program Officer for Environmental Studies
SUSAN N.J. MARTEL, Senior Program Officer for Toxicology
ELLEN K. MANTUS, Senior Program Officer for Risk Analysis
EILEEN N. ABT, Senior Program Officer
RUTH E. CROSSGROVE, Senior Editor
MIRSADA KARALIC-LONCAREVIC, Manager, Technical Information Center
RADIAH ROSE, Manager, Editorial Projects
1
This study was planned, overseen, and supported by the Board on Environmental
Studies and Toxicology.
vi
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OTHER REPORTS OF THE
BOARD ON ENVIRONMENTAL STUDIES AND TOXICOLOGY
Review of the Environmental Protection Agency’s Draft IRIS Assessment
of Formaldehyde (2011)
The Use of Title 42 Authority at the U.S. Environmental Protection
Agency (2010)
Review of the Environmental Protection Agency’s Draft IRIS Assessment of
Tetrachloroethylene (2010)
Hidden Costs of Energy: Unpriced Consequences of Energy Production and
Use (2009)
Contaminated Water Supplies at Camp Lejeune—Assessing Potential Health
Effects (2009)
Review of the Federal Strategy for Nanotechnology-Related Environmental,
Health, and Safety Research (2009)
Science and Decisions: Advancing Risk Assessment (2009)
Phthalates and Cumulative Risk Assessment: The Tasks Ahead (2008)
Estimating Mortality Risk Reduction and Economic Benefits from Controlling
Ozone Air Pollution (2008)
Respiratory Diseases Research at NIOSH (2008)
Evaluating Research Efficiency in the U.S. Environmental Protection
Agency (2008)
Hydrology, Ecology, and Fishes of the Klamath River Basin (2008)
Applications of Toxicogenomic Technologies to Predictive Toxicology and
Risk Assessment (2007)
Models in Environmental Regulatory Decision Making (2007)
Toxicity Testing in the Twenty-first Century: A Vision and a Strategy (2007)
Sediment Dredging at Superfund Megasites: Assessing the Effectiveness (2007)
Environmental Impacts of Wind-Energy Projects (2007)
Scientific Review of the Proposed Risk Assessment Bulletin from the Office
of Management and Budget (2007)
Assessing the Human Health Risks of Trichloroethylene: Key Scientific
Issues (2006)
New Source Review for Stationary Sources of Air Pollution (2006)
Human Biomonitoring for Environmental Chemicals (2006)
Health Risks from Dioxin and Related Compounds: Evaluation of the EPA
Reassessment (2006)
Fluoride in Drinking Water: A Scientific Review of EPA’s Standards (2006)
State and Federal Standards for Mobile-Source Emissions (2006)
Superfund and Mining Megasites—Lessons from the Coeur d’Alene River
Basin (2005)
Health Implications of Perchlorate Ingestion (2005)
Air Quality Management in the United States (2004)
Endangered and Threatened Species of the Platte River (2004)
vii
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Atlantic Salmon in Maine (2004)
Endangered and Threatened Fishes in the Klamath River Basin (2004)
Cumulative Environmental Effects of Alaska North Slope Oil and Gas
Development (2003)
Estimating the Public Health Benefits of Proposed Air Pollution
Regulations (2002)
Biosolids Applied to Land: Advancing Standards and Practices (2002)
The Airliner Cabin Environment and Health of Passengers and Crew (2002)
Arsenic in Drinking Water: 2001 Update (2001)
Evaluating Vehicle Emissions Inspection and Maintenance Programs (2001)
Compensating for Wetland Losses Under the Clean Water Act (2001)
A Risk-Management Strategy for PCB-Contaminated Sediments (2001)
Acute Exposure Guideline Levels for Selected Airborne Chemicals (nine
volumes, 2000-2010)
Toxicological Effects of Methylmercury (2000)
Strengthening Science at the U.S. Environmental Protection Agency (2000)
Scientific Frontiers in Developmental Toxicology and Risk Assessment (2000)
Ecological Indicators for the Nation (2000)
Waste Incineration and Public Health (2000)
Hormonally Active Agents in the Environment (1999)
Research Priorities for Airborne Particulate Matter (four volumes, 1998-2004)
The National Research Council’s Committee on Toxicology: The First 50
Years (1997)
Carcinogens and Anticarcinogens in the Human Diet (1996)
Upstream: Salmon and Society in the Pacific Northwest (1996)
Science and the Endangered Species Act (1995)
Wetlands: Characteristics and Boundaries (1995)
Biologic Markers (five volumes, 1989-1995)
Science and Judgment in Risk Assessment (1994)
Pesticides in the Diets of Infants and Children (1993)
Dolphins and the Tuna Industry (1992)
Science and the National Parks (1992)
Human Exposure Assessment for Airborne Pollutants (1991)
Rethinking the Ozone Problem in Urban and Regional Air Pollution (1991)
Decline of the Sea Turtles (1990)
Copies of these reports may be ordered from the National Academies Press
(800) 624-6242 or (202) 334-3313
www.nap.edu
viii
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Preface
The U.S. Environmental Protection Agency (EPA) released noncancer and
cancer assessments of formaldehyde for its Integrated Risk Information System
(IRIS) in 1990 and 1991, respectively. The agency began reassessing formalde-
hyde in 1998 and released a draft IRIS assessment in June 2010. Much research
has been conducted since the original assessments, and scientists are currently
debating the carcinogenic properties of formaldehyde and the ways that it might
cause cancer. Given the complexity of the issues and the knowledge that the
assessment will be used as the basis of regulatory decisions, EPA asked the Na-
tional Research Council (NRC) to conduct an independent scientific review of
the draft IRIS assessment.
In this report, the Committee to Review EPA’s Draft IRIS Assessment of
Formaldehyde first addresses some general issues associated with the draft IRIS
assessment. The committee next focuses on questions concerning specific as-
pects of the draft assessment, including derivation of the reference concentra-
tions and the cancer unit risk estimates for formaldehyde. The committee closes
with recommendations for improving the IRIS assessment of formaldehyde and
provides some general comments on the IRIS development process.
The present report has been reviewed in draft form by persons chosen for
their diverse perspectives and technical expertise in accordance with procedures
approved by the NRC Report Review Committee. The purpose of the independ-
ent review is to provide candid and critical comments that will assist the institu-
tion in making its published report as sound as possible and to ensure that the
report meets institutional standards of objectivity, evidence, and responsiveness
to the study charge. The review comments and draft manuscript remain confi-
dential to protect the integrity of the deliberative process. We thank the follow-
ing for their review of this report: Margit L. Bleecker, Center for Occupational
and Environmental Neurology; Claude Emond, Université de Montréal; George
L. Delclos, The University of Texas Health Science Center at Houston School of
Public Health; Lynn R. Goldman, George Washington University; Ulrike Lud-
erer, University of California, Irvine; Roger O. McClellan, Toxicology and Hu-
man Health Risk Analysis; Martha S. Sandy, California Environmental Protec-
ix
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x Preface
tion Agency; Jeffrey D. Schroeter, The Hamner Institutes for Health Sciences;
Susan J. Simmons, University of North Carolina, Wilmington; Joyce S. Tsuji,
Exponent; Elizabeth W. Triche, Brown University; Clifford P. Weisel, Univer-
sity of Medicine and Dentistry of New Jersey; Joseph L. Wiemels, University of
California, San Francisco.
Although the reviewers listed above have provided many constructive
comments and suggestions, they were not asked to endorse the conclusions or
recommendations, nor did they see the final draft of the report before its release.
The review of the report was overseen by the review coordinator, Kenneth S.
Ramos, University of Louisville Health Science Center, and the review monitor,
Frank E. Speizer, Harvard Medical School and Harvard School of Public Health.
Appointed by NRC, they were responsible for making certain that an independ-
ent examination of the report was carried out in accordance with institutional
procedures and that all review comments were carefully considered. Responsi-
bility for the final content of the report rests entirely with the committee and the
institution.
The committee gratefully acknowledges Danielle DeVoney, Sue Makris,
Peter Preuss, and Kathleen Raffaele, of the U.S. Environmental Protection
Agency, and Bruce Fowler, of the Agency for Toxic Substances and Disease
Registry, for making presentations to the committee.
The committee is also grateful for the assistance of NRC staff in preparing
this report. Staff members who contributed to the effort are Ellen Mantus, pro-
ject director; Heidi Murray-Smith, program officer; Keri Schaffer, research as-
sociate; James Reisa, director of the Board on Environmental Studies and Toxi-
cology; Norman Grossblatt, senior editor; Mirsada Karalic-Loncarevic,
manager, Technical Information Center; Radiah Rose, manager, editorial pro-
jects; and Panola Golson, program associate.
We thank especially the members of the committee for their efforts
throughout the development of this report.
Jonathan M. Samet, Chair
Andrew F. Olshan, Vice-Chair
Committee to Review EPA’s Draft
IRIS Assessment of Formaldehyde
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Contents
SUMMARY ...............................................................................................................3
1 INTRODUCTION ....................................................................................16
Formaldehyde and the Draft Assessment, 16
The Committee’s Task and Approach, 20
Organization of Report, 22
References, 23
2 REVIEW OF METHODS .......................................................................24
Review of the Methodology of the Draft IRIS Assessment
of Formaldehyde, 25
Summary, 28
References, 28
3 TOXICOKINETICS AND MODES OF ACTION
OF FORMALDEHYDE...........................................................................29
Toxicokinetics, 30
Carcinogenesis: Has a Mode of Action of Formaldehyde
Been Identified?, 44
Use of a Biologically Based Dose-Response Model, 46
Conclusions and Recommendations, 58
References, 60
4 PORTAL-OF-ENTRY HEALTH EFFECTS ........................................64
Irritation, 65
Decreased Pulmonary Function, 71
Noncancer Respiratory Tract Pathology, 74
Asthma, 78
Respiratory Tract Cancers, 83
References, 88
xi
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xii Contents
5 SYSTEMIC HEALTH EFFECTS ..........................................................92
Immunotoxicity, 93
Neurotoxicity, 97
Reproductive and Developmental Toxicity, 102
Lymphohematopoietic Cancers, 108
References, 114
6 REFERENCE CONCENTRATIONS FOR NONCANCER
EFFECTS AND UNIT RISKS FOR CANCER ...................................118
Formaldehyde Reference Concentrations, 119
Formaldehyde Unit Risks For Cancer, 133
Conclusions and Recommendations, 144
References, 146
7 A ROADMAP FOR REVISION ...........................................................151
Critical Revisions of the Current Draft IRIS Assessment
of Formaldehyde, 151
Future Assessments and the IRIS Process, 152
References, 166
APPENDIXES
A BIOGRAPHIC INFORMATION ON THE COMMITTEE
TO REVIEW EPA’S DRAFT IRIS ASSESSMENT OF
FORMALDEHYDE ...............................................................................168
B WEIGHT-OF-EVIDENCE DESCRIPTIONS FROM
U.S. ENVIRONMENTAL PROTECTION AGENCY
GUIDELINES .........................................................................................174
BOXES, FIGURES, AND TABLES
BOXES
1-1 Statement of Task, 20
FIGURES
S-1 Illustration of potential process for identifying an RfC, 13
1-1 Formaldehyde chemical structure, 17
1-2 Formaldehyde concentration in various environments, 18
1-3 Timeline of the development of the draft IRIS assessment, 19
2-1 Elements of the IRIS process, 25
3-1 Schematic representation of the mammalian nasal epithelium, 32
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xiii
Contents
4-1 Odds ratios for physician-diagnosed asthma in children associated
with in-home formaldehyde concentrations in air, 82
5-1 Origins of lymphohematopoietic cancers, 109
5-2 Relative incidence and estimated annual new diagnoses of
common lymphohematopoietic cancer subtypes in the United States, 110
6-1 Illustration of EPA’s process for deriving a reference concentration
for formaldehyde, 120
6-2 Illustration of a potential process for identifying an RfC from a
full database, 132
7-1 New IRIS assessment process, 154
7-2 Elements of the key steps in the development of a draft
IRIS assessment, 155
7-3 Example of an article-selection process, 159
TABLES
3-1 Analysis of 3D CFD Models by Kimbell et al. (2001a,b) and
Overton et al. (2001) for Rat, Monkey, and Human Airways, 41
3-2 Overview of the Conolly et al. BBDR Models, 48
3-3 Effects of Different Parameters on Predicted Results of the
Conolly et al. BBDR Models, 52
6-1 Derivation of Candidate RfCs by EPA, 122
6-2 Cancer Unit Risk Estimates for Formaldehyde, 142
7-1 Criteria for Determining Causality, 157
7-2 Hierarchy for Classifying Strength of Causal Inferences
on the Basis of Available Evidence, 157
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