Commission Proposes Safety Notice For Up Foam Insulation Contracts

The U.S. Consumer Product Safety Commission voted unanimously yesterday to propose a regulation requiring the disclosure of safety information for urea formaldehyde (UF) foam insulation. The disclosure would alert consumers that the product may release formaldehyde gas which can adversely affect their health.

Persons installing UF foam insulation will be required to include the safety information on all sales contracts for the product. The information must appear on the same contract page as the consumer's signature and must be provided to the consumer before the product is installed. (A complete text of the notification language is attached to this news release.)

Following a 60-day period of public comment on the proposed safety notification, the Commission could approve a final rule as early as mid-October, 1980, with the requirement becoming effective six weeks later.

The Commission already has received more than 1,000 complaints from consumers who reported adverse health effects after UF foam insulation was installed in their homes. CPSC staff estimates that the level of complaints now reflects at least 2,500 people who have suffered symptoms of exposure to formaldehyde gas from UF foam insulation.

In a formaldehyde study commissioned by CPSC early last year the National Academy of Sciences recommended that consumer. exposure to formaldehyde be reduced to the lowest practical level. NAS health authorities concluded that "information from controlled human studies and complaint-related investigations suggests that, even at extremely low airborne concentrations, a proportion of the population will respond with some irritation."

Today's proposal is intended to ensure that consumers promptly are given accurate safety information about the insulation before it is installed. CPSC staff this summer will continue to examine the potential toxicity and carcinogenicity of formaldehyde, and in September may request the Commission to consider whether additional regulatory actions are needed for UF foam insulation, including a possible safety standard or a nationwide ban of the product.

The safety information must appear above the contract signature line, and will be emphasized by its enclosure in a ruled box, distinct coloration and the use of large bold-faced printing.

The safety information will enable consumers to make an informed decision as to whether to purchase the product, and responds to consumers' requests for uniform safety information repeatedly voiced during CPSC's four regional hearings on UF foam insulation which ended in February.

Currently, safety information disclosed to consumers varies among manufacturers and states. While the CPSC action may not prevent states and local governments from imposing different requirements, the safety information must appear on contracts regardless of individual state mandates.

UF Foam And Formaldehyde

UF foam insulation is a cellular plastic material used for thermal insulation. Installers mix the product at the job- site by combining a Urea formaldehyde-based resin with a foaming agent to yield a product with the consistency of shaving cream. By means of pressurized air, the foam is then pumped through a hose into holes drilled in a structure's exterior walls, where it hardens into a self-supporting material.

After installation, formaldehyde gas can be released into consumers' homes. The release of the gas may depend on such factors as temperature, humidity, the architecture of the building and the installation techniques employed.

Since 1978, when CPSC began focusing on UF foam insulation, the staff has conducted 218 in-depth investigations of consumer complaints of adverse health effects. During interviews, consumers have reported symptoms ranging from short-term discomfort to chronic physical impairment, including the loss of visual acuity, reduction in lung function and sensitization to other formaldehyde sources.

The investigations revealed that 28 people required hospitalization following installation of the insulation, primarily for respiratory distress, and that 68 families were forced to vacate their homes or were unable to move into a new home because of the release of formaldehyde gas.

CPSC staff also was able to obtain measurements of formaldehyde gas levels inside 58 of the homes. The samples ranged from very low levels of less than 1 part per million to a number of cases with levels greater than 1 ppm.

CPSC staff has been informed that most of the inexpensive remedies proposed to alleviate formaldehyde gas problems in homes, such as ventilation, do not always adequately control the release of formaldehyde gas. In addition, symptoms may be Slow in appearing 20 per cent of the complainants reported that it took two months or longer for symptoms to appear and in some cases the health problems persisted even after the UF foam insulation had been extracted from the home walls.

CPSC staff currently estimates that more than 500,000 homes in the U.S. have been insulated with UF foam. By the end of 1980, another 60,000 to 80,000 homes will have been insulated with the product, about the same number of installations in 1979, according to staff projections.

The great majority of UF foam installations are performed in older homes rather than in newly constructed residences. The product itself comprises approximately five per cent of the entire domestic insulation market, according to CPSC staff and industry estimates.

As currently proposed, the safety information does not address the possible long-term health effects associated with exposure to formaldehyde. However, the Commission may expand the label to cover concern over chronic health effects, such as the potential of formaldehyde to cause cancer, depending on information to be developed during the comment period this summer.

A number of scientific studies and assessments remain to be completed before any further regulatory steps can be taken. These include:

-- Completion of a two-year laboratory animal study on the effects of the inhalation of formaldehyde gas. The study is being conducted by the Battelle Institute for the Chemical Industry Institute for Toxicology (CIIT). As of January, 1980, a significant proportion of laboratory rats had developed a rare form of nasal cancer following exposure to formaldehyde gas at 15 ppm. Final laboratory analysis of the study is expected to begin in June, 1980.

-- Recommendations by a federal panel of scientific and health experts who are assessing the human health implications of CIIT's findings and other health studies.

The proposed notice of safety information applies only to retrofit applications of UF foam in private residences, and not to uses in commercial buildings, recreational facilities or schools. At this time the rule also does not apply to installations in new homes or to homes which already contain the insulation which then are sold to another consumer. However, the Commission wishes to receive public comments on the possible expansion of the rule to cover new homes and commercial structures.

The proposal will be published soon in the Federal Register to commence a 600day public comment period. Comments should be addressed to Office of the Secretary, U.S. Consumer Product Safety Commission, Washington, D.C., 20207.

Safety Information

-- This product may release formaldehyde gas into your home over a long period of time.

-- Formaldehyde gas may cause eye, nose, and throat irritation, coughing, shortness of breath, skin irritation, nausea, headaches and dizziness. People with respiratory problems or allergies may suffer more serious reactions, especially persons allergic to formaldehyde.

-- The symptoms may appear immediately, or not until months after installation.

-- Use of the insulation in attics, ceiling, and interior walls increases the likelihood of releasing formaldehyde gas into your home. In some instances the formaldehyde gas cannot be controlled by ventilation or other inexpensive means.

-- If you have health concerns, call your doctor. Also, contact (installer-phone) or (material supplier-phone) immediately.

The U.S. consumer Product Safety Commission requires the above notice of performance and technical information related to safety.