The Environmental Protection Agency (EPA) is proposing to update several voluntary consensus standards in the Agency's formaldehyde standards for composite wood products regulations under the Toxic Substances Control Act (TSCA). These new standards primarily update test methods, providing "manufacturers and testing laboratories with an additional, internationally recognized tool to help ensure consistent, high-quality emissions data across the industry.

EPA is also proposing to conform these updated standards to the scope and definitional sections in the final rule and to incorporate by reference a new small-scale quality control chamber test method, similar to the current methods already incorporated by reference. 

The proposal was published in the Federal Register on Feb. 11. Comments regarding the proposal must be received on or before March 13, 2026, according to the publication in the Federal Register. Comments, identified by docket identification (ID) number EPA-HQ-OPPT-2017-0245, can be submitted using the Federal eRulemaking Portal at https://www.regulations.gov.

Calculating the risk

In a formaldehyde-related announcement in December 2025, the EPA updated how it calculates risk to workers. The Draft Risk Calculation Memorandum for Formaldehyde under TSCA for Public Comment does not dispute that there is a formaldehyde health risk, but enhances the scientific rigor of the underlying information used to support the risk determination.

In a Jan. 30 letter to the Environmental Protection Agency, Keith Christman, president, Decorative Hardwoods Association, expressed the organization’s “strong support” for the Updated Draft Risk Calculation Memorandum for Formaldehyde, especially the EPA’s revision of its formaldehyde inhalation risk assessment toward a threshold-based risk assessment framework. DHA represents North American manufacturers of hardwood plywood, engineered wood floors and hardwood veneer. 

“We commend EPA for its rigorous and transparent reassessment of formaldehyde risks,” Christman wrote. “We support EPA’s revision of its formaldehyde inhalation risk assessment to reflect the best available science.”

He said that the revised approach is grounded in the latest scientific evidence and stakeholder input. “We particularly support EPA’s reliance on controlled human exposure studies, which provide robust, directly relevant data for evaluating health effects. This evidence-based methodology ensures that regulatory decisions are anchored in real-world exposures and outcomes, fostering both health protection and regulatory credibility.”

The EPA, in the February Federal Register announcement, detailed the quality control test method it supports. The agency proposes to add ISO 12460-2:2024(en), Wood-based panels—Determination of Formaldehyde Release—Part 2: Small-scale Chamber Method (Ref. 13), as a quality control test method in 40 CFR 770.20(b)(1) and to IBR the standard in 40 CFR 770.99.

According to the Register, the standard was approved through ISO and describes the procedure for using a small-scale chamber test method to test formaldehyde emissions from wood products under defined test conditions of temperature, relative humidity, loading and air exchange rate by measuring the concentrations of formaldehyde in air from samples of a specified surface area. This standard is a small-scale quality control chamber test method that EPA is proposing to incorporate by reference as an allowable alternative quality control test method, due to its similarity to other standards currently incorporated by reference for quality control methods, and to allow regulated entities to make use of the wider range of analytical methods the standard allows, such as laser absorption spectroscopy.

Sensory irritation 

In the December 2025 updated draft risk calculation for formaldehyde, the EPA proposed using acute sensory irritation (eye/throat irritation) as the most sensitive endpoint for setting safety standards, rather than cancer risk. The EPA suggests that keeping exposure levels low enough to prevent irritation if exposure levels are at 0.3 ppm or less, for “any duration,” individuals are protected “against all effects, including cancer.”

The DHA also voiced its support for the EPA’s selection of sensory irritation as the health-protective endpoint is fully justified by the scientific literature. “The weight of the scientific evidence demonstrates that sensory irritation is the most sensitive and biologically relevant endpoint for inhalation exposure to formaldehyde. Thus, protecting against sensory irritation is protective of downstream effects, including chronic non-cancer and cancer outcomes, under a threshold mode of action. EPA’s revised framework appropriately reflects these conclusions and aligns with recommendations from EPA’s own scientific advisory bodies,” according to the letter.

Sidebar: Voluntary consensus standards included in the proposal:

• ANSI A190.1-2022, Product Standard for Structural Glued Laminated Timber (ANSI)
• ASTM D5582-22, Standard Test Method for Determining Formaldehyde Levels from Wood Products Using a Desiccator (ASTM)
• ASTM D6007-22, Standard Test Method for Determining Formaldehyde Concentrations in Air from Wood Products Using a Small-Scale Chamber (ASTM)
• ASTM E1333-22, Standard Test Method for Determining Formaldehyde Concentrations in Air and Emission Rates from Wood Products Using a Large Chamber (ASTM)
• BS EN ISO 12460-3:2023, Wood-based panels—Determination of formaldehyde release—Part 3: Gas analysis method (BSI)
  Wood-based panels—Determination of formaldehyde release—Part 3: Gas analysis method (BS EN ISO)
  PS 1-22, Structural Plywood (NIST)