May 1, 1996

Office of Prevention, Pesticides and Toxic Substances

Mr. Ed Freyermuth
Superlite Block Inc.
4150 West Turney Avenue
Phoenix, Arizona 85019

Dear Mr. Freyermuth:

This is in response to our telephone conversation of April 30, 1996, in which we discussed issues that had been raised, on your behalf, by Mr. Randall Pence of the National Concrete Masonry Association in his March 26, 1996 letter to Congressman John Shadegg of Arizona. These issues concerned: (1) the regulatory status of urea-formaldehyde foam insulation (UFFI), particularly with regard to its use in insulating concrete masonry walls, and (2) the potential for UFFI to release formaldehyde gas under certain environmental conditions.

In the early 1980s, the Consumer Product Safety Commission (CPSC) acted in response to numerous consumer complaints and used its regulatory authority to ban the practice of injecting UFFI into the wall cavities of homes. CPSC had received complaints from residents of some of these homes who claimed they had experienced irritation effects resulting from exposure to high levels of formaldehyde, a component of UFFI. Often, these high levels occurred shortly after UFFI had been installed. At the time, public health concerns were also growing for formaldehyde in response to the results of industry sponsored testing that had demonstrated the potential of formaldehyde to cause cancer in laboratory animals that had been exposed to the chemical via inhalation.

CPSC's restriction on UFFI insulating practices was short-lived, quickly overturned by an Federal court on grounds relating to the procedures used by CPSC to issue the regulation. However, the initial imposition of the ban and the continuing concern for the potential health effects of formaldehyde exposure effectively ended, in the early 1980s, the practice of installing UFFI in homes. It is EPA's understanding that CPSC elected not to initiate regulatory proceedings to reimpose the ban because UFFI installation practices had generally ceased. Subsequently, several States either imposed their own restrictions on the use of UFFI or required that the owners of homes that had been insulated with UFFI disclose this information to potential buyers at the time the home was sold.

Regarding the use of UFFI in concrete masonry and its susceptibility to degradation, I am enclosing a copy of a technical note prepared in 1985 by the U.S. Department of Commerce's National Bureau of Standard (now called the National Institute of Standards and Technology (NIST): Urea-Formaldehyde Foam Insulations: A Review of Their Properties and Performance. It addresses, among other topics, what is known about of the effects of UFFI on concrete masonry and the environmental factors that can cause UFFI to breakdown and release formaldehyde gas.

If I may be of further assistance to you, please call me at 202-260-2134.

Sincerely,
George Semeniuk, Ph.D.
Formaldehyde Project Manager
Office of Pollution Prevention and Toxics (7405)