In December 2021, NFDA submitted comments to the Environmental Protection Agency (EPA) presenting a strong case against restricting use of formaldehyde by funeral service professionals. The comments were bolstered by results from a new formaldehyde exposure study commissioned by NFDA. We have recently learned that this study has been accepted for publication in the July 2022 issue of the peer-reviewed Journal of Occupational and Environmental Hygiene.
The publication of NFDA’s study, “Assessment of formaldehyde exposures under contemporary embalming conditions in U.S. funeral homes,” in a peer-reviewed journal demonstrates that the NFDA research was scientifically sound and its conclusions were valid. This is critically important because as the EPA evaluates whether formaldehyde presents an unreasonable risk to human health or the environment, it will base its decision on existing scientific data.
Unfortunately, the funeral profession lacked recent, reliable scientific data related to the use of formaldehyde in embalming. Available studies were mostly conducted prior to the 1980s and do not represent accurate embalming practices today.
This new, NFDA-commissioned study expands the body of research pertaining to the safe use of formaldehyde in the funeral service profession and offers new evidence upon which the EPA can base its decisions.
Why is the EPA reviewing formaldehyde?
The EPA selected formaldehyde for a risk assessment under the Toxic Substances Control Act, which requires the agency to periodically conduct assessments to determine whether certain chemicals present an unreasonable risk to human health or the environment. If the EPA finds a chemical poses a risk, it can impose controls or restrictions on its use.
We recognize that embalming with formaldehyde is critical to your work and want to preserve your ability to use it safely and responsibly. The NFDA Board of Directors and staff has your back on this critical issue and NFDA has been actively participating in this risk assessment process from the very beginning, engaging in dialogue and submitting comments as we have opportunity to do so.
Why did NFDA conduct a study?
As it conducts its risk assessment, the EPA will use available scientific data. Existing research regarding the use of formaldehyde in the funeral service profession is more than four decades old and does not reflect the way funeral professionals use formaldehyde today.
To show that funeral service professionals understand how to safely use formaldehyde, NFDA wanted to provide the EPA with more current data that characterizes the typical preparation room in in the 21st Century.
To ensure this study was scientifically sound, NFDA hired a scientific consulting firm to conduct the exposure study on the use of formaldehyde in embalming. This scientific consulting firm is recognized worldwide for its technical capabilities and experience working with the EPA on chemical risk assessments.
What did we learn from the results of the study?
The consulting firm collected data at 13 funeral homes of varying ages, geography and number of annual embalming cases in an effort to include a range of exposure scenarios for workers in the profession.
The results of this study, which are highlighted in comments NFDA submitted to the EPA, present a stark contrast to existing scientific data and show that the level of exposure to formaldehyde for funeral directors and embalmers is less than current permissible exposure limits.
Our study found that the mean task-exposure concentration of formaldehyde during an active embalming was 0.68 ppm. This falls below the current permissible eight-hour exposure limit of 0.75 ppm and is far less than the short-term exposure limit of 2 ppm.
The new data that NFDA shared with the EPA in its comments demonstrate that trained funeral service professionals can effectively manage their exposure to formaldehyde and use it safely and responsibly.
What’s next?
This EPA risk assessment is a multi-phase process that is expected to last until 2025. We will keep you informed as we continue to engage in this multi-year formaldehyde risk assessment process on your behalf and that of the profession.
As always, we value your opinions as we continue to engage with the EPA on this important issue. There will be plenty of opportunities for you to share your thoughts and questions during this lengthy process. In the meantime, if you have any questions, please contact our Advocacy team at advocacy@nfda.org.