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Green Chemistry and Design Formaldehyde and HBCD in Building Products Project

The intent of this project is to demonstrate the extent to which state grant support can stimulate green chemistry and design projects in the private sector.

This web page will serve as a clearinghouse for updates on the implementation of this project and for other information supporting or generated by this project.

MPCA staff thanks the U.S. Environmental Protection Agency's Pollution Prevention Program for its grant that supported this project.

Notices

Use of Formaldehyde and HBCD in Minnesota

The Minnesota Pollution Control Agency has completed a project with the Stratford Companies to work with the MPCA to assess the presence and use of formaldehyde and Hexabromocyclododecane (HBCD) in Minnesota’s composite and fabricated wood building and furnishing products by manufacturers, architects, engineers and contractors (the value chain). Summaries of the findings from these surveys can be seen below. Copies of the final white papers are available by request to Mark Snyder.

Project for surveying the use of formaldehyde in Minnesota building products and other manufacturing

The Stratford Companies (Stratford) conducted a survey of use of formaldehyde in Minnesota building products.

The following survey questions were developed:

  • Contact information
  • What types of products do you manufacture?
  • Do any of your products contain formaldehyde?
  • Are there any products that you specifically add or incorporate formaldehyde?
  • If your product(s) contain formaldehyde in any form, do you have any current or future plans to use an alternate material?
  • If yes, you plan to investigate other materials, what alternate material do you plan to investigate?   
  • Do you wish your company name to be used in the report to the State?         
  • Any additional comments?

Questionnaires to survey the use of formaldehyde were sent to 220 businesses. Stratford received 14 survey results (6.3% response rate) and conducted over 50 interviews and hundreds of informal conversations with responding companies about their use of formaldehyde.

MPCA P2 staff will weigh the findings of these surveys along with other program factors to determine if the further phases of outreach and assistance and support and evaluation are warranted.

Formaldehyde Survey of Use

Value chain

Formaldehyde is a colorless flammable gas and is naturally produced in small amounts by trees, humans, and other organisms. Formaldehyde is also commercially produced for use in binding resins, preservatives, disinfectants, glues and building materials such as engineered wood. Formaldehyde is also used to make various plastics, fabric finishes, and automobile components. Minnesota Department of Health included formaldehyde, CAS# 50-00-0, in its lists of Chemicals of High Concern and Priority Chemicals.

Alternatives

Urea formaldehyde based resins are the most commonly used resin binders in engineered wood for building products (particle board, medium density fiberboard, and plywood).

PDF DocumentAlternative composite wood binders include:

  • Modified urea formaldehyde resins with scavenger additives, such as melamine, to reduce the rate of emissions of formaldehyde;
  • Alternate formaldehyde resins, such as phenol formaldehyde, which cure at the factory during manufacture and hence have much lower formaldehyde emissions in use than urea formaldehyde;
  • Alternate fossil fuel-based binders containing no added formaldehyde, such as methylene diphenyl diisocyanate;
  • Alternate binders based on renewable resource materials, such as soy flour.

Outreach Methodology

Through collaboration with partners and research of NAICS data, over 2,000 Minnesota businesses were identified as potential users of formaldehyde. The project team used insight from partner interviews to narrow the field of businesses to best assess the presence and use of formaldehyde in Minnesota’s composite and fabricated wood building and furnishing products within the value chain.

Businesses that had these manufacturing processes in their NAICS code description, had website related information, and/or had related association participation were contacted with the web based questionnaire:

  • Glues and binding resins;
  • Wood preservatives and disinfectants;
  • Textile and furniture manufacturers.

Survey Findings

Respondents are listed by business categories:

  • Forest Product Distributors: 3 businesses – Certified Wood Products, Wood from the Hood, Structural Wood Corporation
  • Sustainable Commercial and Institutional Furniture Manufacturers – 3 businesses – Baltix Sustainable Furniture LLC, Lexington Manufacturing, and an anonymous response
  • Coated Fine Paper and Specialized Cellulose Pulp Manufacturers: 1 business – Sappi Paper Company
  • Engineered Wood Products Manufacturers: 1 business – Louisiana Pacific Corporation (or LP Building Products)
  • Resin Impregnated Fabrics Manufacturers: 1 business – an anonymous response
  • Other Businesses: 5 businesses – Green Plains Otter Tail, Poet Biorefining, Knauf Insulation, JL Larson, Valera Renewables

Questionnaire responses and informal/formal interviews have indicated that the use of urea formaldehyde, modified urea formaldehyde with scavenger additives, and phenol formaldehyde is primarily found in the state of Minnesota in the form of resin and wood preservatives used in fabricated wood building and furnishing products. Formaldehyde is added to products as component technology sourced from out-of-state manufacturers.

Questionnaire respondents disclosed voluntarily that formaldehyde was a part of the following products manufactured in Minnesota:

  • Forest products;
  • Commercial and institutional office furniture;
  • Resin impregnated into fiberglass, carbon fiber, Kevlar, Teflon, foam, and other fabrics imported into Minnesota;
  • Paper flakes as a component material within pressed exterior lap siding, trim, fascia and soffit sourced from out-of-state manufacturers.

Review of information shows sensitivity for value chain businesses to quantify what percentage of formaldehyde is used and knowledge of safer alternative materials. Subsequent interviews with respondents and other businesses indicate that significant research is needed to inventory possible formaldehyde presence in rebranded and wholesale glues, finishes and fabrics. Research also substantiated that the vast majority of businesses that are adding formaldehyde to their products are interested in using alternatives. Many of them have begun to switch to alternatives for several products.

Interviews with manufacturers and architects confirm that businesses within the formaldehyde value chain have sought to reduce or highly regulate the amount of chemical used. Drivers that are pushing the value chain away from formaldehyde include:

Conclusion

Formaldehyde is currently used in thousands of products manufactured and sold in Minnesota in the form of adhesives, bonding agents and solvents.

Key findings indicate:

  • Indoor air quality health concerns have increased the knowledge base among architects and engineers to research the amount of formaldehyde used in various building industry products. Increasingly, product specifications recognize formaldehyde as a concern by calling for safer functional alternatives.
  • Building product resellers in Minnesota are moving towards GreenGuard-certified products that limit off-gassing levels and provide third party validation.
  • Commercial furniture manufacturers are reducing the use of urea formaldehyde as a component chemical across product lines to ensure compliance with CARB standards. Commercial furniture companies are beginning to offer optional “No Added Urea Formaldehyde” wood in their products.
  • Unregulated, imported engineered wood products may be the single largest contribution of formaldehyde emissions.

Stratford’s white paper may be requested by emailing Mark.Snyder@state.mn.us

Project for surveying the use of hexabromocyclododecane in Minnesota building products and other manufacturing

The Stratford Companies (Stratford) conducted surveys of use of hexabromocyclododecane (HBCD) in Minnesota building products.

The following survey questions were developed:

  • Contact information
  • What types of products do you manufacture?
  • Do any of your products contain HBCD?
  • Are there any products that you specifically add or incorporate HBCD?
  • If your product(s) contain HBCD in any form, do you have any current or future plans to use an alternate material?
  • If yes, you plan to investigate other materials, what alternate material do you plan to investigate?     
  • Do you wish your company name to be used in the report to the State?         
  • Any additional comments?

Questionnaires to survey the use of HBCD were sent to 55 businesses. Stratford received 10 survey results (16% response rate) and conducted over 8 interviews and approximately 25 informal conversations with responding companies about their use of HBCD.

MPCA P2 staff will weigh the findings of these surveys along with other program factors to determine if the further phases of outreach and assistance and support and evaluation are warranted.

HBCD Survey of Use

Value chain

HBCD is a brominated fire retardant. HBCD is a group of different stereoisomers. Stereoisomers are substances which have the same chemical composition, yet differ in the spatial arrangement of their atoms.  MDH included hexabromocyclododecane, CAS# 25637-99-4, and 1,2,5,6,9,10 hexabromocyclododecane, CAS # 3194-55-6, in its list of Chemicals of High Concern. MDH included 1,2,5,6,9,10 hexabromocyclododecane, CAS # 3194-55-6, in its list of Priority Chemicals

HBCD is typically added to extruded polystyrene foam (XPS) and expanded polystyrene foam (EPS) which is used as insulation in buildings. HBCD may also be used in upholstered furniture, automobile interior textiles, car and truck cushions and insulation blocks, packaging material and in limited use in electronic equipment and wiring. HBCD is used in the textile backer for nylon carpet tiles and in military fabrics.

Alternatives

Up until 2013, there was no acceptable and readily available alternative to HBCD flame retardant in EPS and XPS. In the past few years, both Dow and Flint Hills Resources have announced they are developing EPS and XPS products with new polymeric HBCD-free flame retardants.

Dow announced its development of an alternative flame retardant in 2013. It is expected to hit the market between 2013 and 2015.

Flint Hills Resources expects to release its alternative  resin on the market in 2013.

New polymeric flame retardants are discussed in U.S. EPA’s Design for the Environment (DfE) draft assessment which was released September 24, 2013.

Outreach Methodology

Through collaboration with partners and research of NAICS data, Stratford determined that EPS and XPS producers in Minnesota and major EPS and XPS brands that are sold in Minnesota are the two pieces that make up the overwhelming majority of HBCD use in the state.

Survey Findings

When businesses were contacted Stratford found that there was limited knowledge of what HBCD is and how it relates to their business.

HBCD in Building Products Survey respondents included the following business categories:

  • Expanded Polystyrene Foam Manufacturers: 2 Businesses – Styrotech, PolyFoam Inc.
  • Extruded Polystyrene Foam Manufacturers: 1 Business – Clariant Corporation
  • Other Businesses:  7 Businesses -  Baltix Sustainable Furniture LLC, Plasti Dip International, MG Electronic Chemicals, Ceramic Industrial Coatings, Interplastics Corp, and 2 anonymous responses

Questionnaire respondents disclosed voluntarily that HBCD was a part of the following products manufactured in Minnesota:

  • Expanded Polystyrene Foam (EPS)
  • Extruded Polystyrene Foam (XPS)

Subsequent interviews with respondents and other businesses indicate that a significant movement is being made toward non-persistent, bioaccumulative, and toxic (non-PBT) polymeric alternatives that will arrive on market in the fall of 2013. Interviews with manufacturers and architects confirm that businesses within the HBCD value chain have sought to move to non-PBT alternatives.  Drivers that are pushing the international value chain away from HBCD include:

Conclusion

Questionnaire responses and informal/formal interviews have confirmed that the use of HBCD in the Minnesota building industry is overwhelmingly the EPS and XPS industries. HBCD is added to products as component technology sourced from out-of-state manufacturers as premixed solutions. The building industry is largely unaware of the presence of HBCD in their products or the potential harms of this persistent, bioaccumulative and toxic chemical.

HBCD is being phased out by regulation in both Canada and the European Union.  In October of 2012, the Stockholm Convention on Persistent Organic Pollutants proposed a global ban on HBCD. The proposed ban was approved in May 2013, but will require ratification by the U.S. Senate and changes to the Toxic Substances Control Act to be implemented in the U.S.
In late 2013, the first domestically produced EPS and XPS products with polymeric flame retardants will come onto market.  If these products prove to be safe and effective, they may replace HBCD in EPS and XPS products from major manufacturers.

Imported products may use HBCD in unknown quantities.

Labeling that HBCD is a component of fire retardant products would build awareness on the chemical. An investigation into the volume of HBCD in all EPS and XPS foam products manufactured or sold in the State would illustrate the degree of concern HBCD poses to humans and the environment.

Stratford’s white paper may be requested by emailing Mark.Snyder@state.mn.us

Background

Formaldehyde is monitored and regulated by a number of local, state, national and international agencies and organizations.  It is pervasive, causes eye and respiratory effects including asthma, and is carcinogenic. The U.S. EPA has included hexabromocyclododecane (HBCD) in their Chemicals Action Plans, which summarize available hazard, exposure, and use information on chemicals; outline the risks that each chemical may present; and identify the specific steps the Agency is taking to address those concerns. HBCD is used in expanded polystyrene foam (EPS) in the building and construction industry and is highly toxic to aquatic organisms. It also presents human health concerns based on animal test results indicating potential reproductive, developmental and neurological effects.

Using criteria established in the 2009 Minnesota Toxic Free Kids Act, the Minnesota Department of Health (MDH) listed formaldehyde and HBCD as Priority ChemicalsExit to Web not because of their direct use or presence in children’s products but because of children’s exposure (especially indoors) through other products, primarily building materials.

MPCA conducted a project on formaldehyde and HBCD and their use in Minnesota building products and other manufacturing. The agency is approaching this project in phases.

Phase 1 of this project consisted of outreach to survey use. For formaldehyde, Minnesota sites producing composite products and reporting formaldehyde releases were partners for assessing current conditions and opportunities.  This phase also focused on Minnesota companies purchasing composite wood products from out-of-state for incorporation into fabricated wood products.  With these types of companies, research was needed to inventory possible formaldehyde presence in glues, finishes and fabrics. For HBCD, the focus was on Minnesota companies in the building and construction industry involved with its most common uses, such as in expanded polystyrene foam (EPS) and extruded polystyrene foam (XPS) produced for insulation.

Minnesota has a significant number of companies using or manufacturing plastics, elastomers and resins, as well as a large number of companies producing various types of packaging which incorporate coatings and laminations using various plastics-related materials containing or produced with formaldehyde and HBCD and many of the other Minnesota Priority Chemicals. 

If findings deem further action appropriate, consideration will be made for:

Phase 2: Outreach and assistance
Phase 3: Support and evaluation

MPCA contact: Mark Snyder, 651-215-0222

Last modified on October 16, 2013 09:12

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