Environmental Permitting

Can Your Clothes Make You Sick? GAO Looking at Formaldehyde in Clothing

While there are no federal limits on formaldehyde in clothing, a recent report by the Government Accountability Office (GAO) may cause Congress and advocacy groups to put pressure on the Consumer Product Safety Commission (CPSC) to revisit the feasibility of imposing such limits.

Formaldehyde is a heavily regulated substance and one of a handful of toxic chemicals with which the general public is familiar. Formaldehyde is best known as a preservative and disinfectant used in laboratories and mortuaries. It is also widely used in consumer products such as pressed wood, glues and adhesives, and cosmetics.

The substance made news headlines after Hurricane Katrina when it was reported that formaldehyde emissions from pressed wood products used in temporary housing provided by FEMA were making people sick. The revelations resulted in the Formaldehyde Standards for Composite Wood Products Act, which was signed by President Obama in July 2010. Under the statute, beginning in 2013, manufacturers will be required to comply with formaldehyde emissions limits for hardwood plywood, medium-density fiberboard, and particle board.

Given that some clothing—generally garments made of cotton and other natural fibers—is treated with resins containing formaldehyde primarily to enhance wrinkle resistance, in 2008 Congress added a provision to the 2008 Consumer Product Safety Improvement Act. Specifically, the law directed GAO to conduct a study on the risks posed to consumers by formaldehyde in clothing.

GAO refers to EPA research indicating that formaldehyde is a probable human carcinogen when inhaled. (The federal designation for formaldehyde was recently changed from reasonably anticipated to be a human carcinogen to known human carcinogen.) But testing suggests that the levels of formaldehyde in clothing sold in the United States may not be high enough to create a credible cancer risk. However, research has also shown that formaldehyde in clothing may bring about allergic contact dermatitis, which can cause swelling, blisters, scaling, and flaky dry skin that can itch or burn. People with allergic contact dermatitis caused by contact with formaldehyde in clothing have generally become hypersensitive to the chemical through previous exposure.

GAO notes that in the absence of regulations or guidance, consumers often do not know that they are purchasing clothing containing formaldehyde. For example, unless the level of formaldehyde in a product reaches 10,000 parts per million (ppm), a level highly unlikely in any clothing, there are no requirements for retailers to state on labels that formaldehyde is present in articles for sale. Neither is there information associated with clothing sales informing for the public that physical reactions to formaldehyde may worsen in hot, humid weather. Also, some formaldehyde concentrations may be lessened by washing before wearing; however, after multiple washings, resins can begin to break down and more formaldehyde may be released. Government or industry may convey this information to consumers, but right now, there is no requirement to do so.

Inhalation of Formaldehyde

Formaldehyde is produced naturally in the environment and is found in low levels in people and most living things. Inhalation of formaldehyde can cause discomfort or nausea stemming from the chemical’s pungent odor; irritation of the eyes, nose, and throat; exacerbation of asthma; and changes at the cellular level that may lead to the development of tumors. EPA lists formaldehyde as a hazardous air pollutant (HAP) under the CAA, and EPA’s HAP regulations place limits on emissions of formaldehyde into the atmosphere. Formaldehyde is also a listed hazardous waste under the Resource Conservation and Recovery Act (RCRA).

However, historically, the primary health concerns about formaldehyde have focused on indoor risks, particularly in occupational settings. The current OSHA regulation, among other things, limits airborne exposure to 0.75 parts of formaldehyde per million parts (ppm) of air over an 8-hour workday; sets a short-term exposure limit of 2 parts formaldehyde per million parts of air; and includes a hazard communication requirement pertaining to formaldehyde, all mixtures or solutions composed of greater than 0.1 percent formaldehyde (equivalent to 1,000 ppm), and materials capable of releasing formaldehyde into the air, under reasonably foreseeable conditions of use, at concentrations reaching or exceeding 0.1 ppm.

The National Institute for Occupational Safety and Health has established nonenforceable guidelines for formaldehyde exposure and recommends an occupational exposure limit over an 8-hour workday of 0.016 ppm and a 15-minute ceiling of 0.1 ppm in the air.