By: Ed Stuber
If you’ve been following regulatory activity around chemical exposure, you know that formaldehyde has remained a complex and evolving topic. In December, the U.S. Environmental Protection Agency (EPA) released updated draft risk evaluations that could again shift how industries assess and manage formaldehyde exposure. While still in the proposal stage, these revisions signal potential changes in occupational, industrial, and environmental expectations.
What’s Changing in the Updated Draft
EPA’s proposal includes several key updates designed to refine and modernize its approach to formaldehyde risk:
New Point of Departure: 0.3 ppm
The draft introduces a new Point of Departure (POD) of 0.3 ppm, representing the threshold from which EPA begins determining risk. This revised value could influence future exposure limits, risk assessments, and workplace mitigation strategies.
Revised Conditions of Use
The updated draft removes five previously evaluated conditions of use from the “unreasonable risk” category. EPA notes that these specific scenarios no longer exceed benchmark levels based on improved data and updated analytical methods.
Replacement of the January 2025 Evaluation
This proposal is intended to replace the risk evaluation finalized in January 2025. The updated draft reflects new modeling, additional exposure data, and a refined methodology.
Ongoing Work on Risk Management
EPA emphasizes that it is still revising its formaldehyde risk management rule. That process will continue even as the revised evaluation moves through review and comment periods. For industrial hygienists, this means requirements may shift again as EPA aligns the risk evaluation and risk management components.
Timeline and Opportunities to Comment
Stakeholders—including industrial hygienists, manufacturers, healthcare facilities, laboratories, and building-material producers—can provide input on the updated draft.
- Public comment deadline: February 2, 2026
- Full proposal available through the Federal Register
What It Means for Industrial Hygiene Programs
While the updated draft does not immediately change compliance obligations, IH practitioners should begin reviewing potential impacts:
- Assess whether current monitoring strategies align with the new POD.
- Re-evaluate exposure scenarios previously considered low-risk.
- Prepare for future adjustments to engineering controls or administrative practices once EPA finalizes its approach.
- Stay informed as EPA advances risk management revisions.