WAKE UP, AMERICA

Since we are all structured differently, we react differently when exposed to chemicals in the home or workplace.  One example of this occurred during the Vietnam War, i.e., not all soldiers suffered permanent injury when exposed to the defoliant Agent Orange, but many did have permanent injuries, mental and/or physical, due to longtime exposure. The sad part of the story is that, for many years, the government refused to treat these illnesses as war-related, and when it was finally determined to be related, many veterans were deceased.  This allowed for a relatively smaller budget amount to be applied to these illnesses – a fact that makes one wonder if this was what the government sought from the start.  Moreover, there was a chemical exposure during the Gulf War that left many service people no longer able to serve, but again, the government stalled in providing treatment for these service-connected disabilities.  Finally, when treatment was provided, it appeared to be with the knowledge that the budget amount would not be overwhelming.

Damning Evidence Against HUD and EPA

The background to the 1984 HUD regulation for Manufactured Home Construction and Safety Standards, contained in Volume 49, Federal Register 31996-32003 dated 8/9/84, shows damning evidence that HUD and EPA were controlled by the industrial lobby, and the consumer comments were ignored.  Section I-D of that background describes a National Manufactured Home Advisory Council of 24 members divided equally among industry, government agencies, and consumer groups.  That section also describes three days of workshop sessions by council subcommittees held in September 1983 with related reports available for public inspection.  However, when I requested a review of the reports in October 1993, I was informed that they were destroyed.  This was highly unusual destruction since ten years had not elapsed since the 8/9/84 issuance date of the regulation.

Section II-B-1 of the background states that State agencies endorsed the use of an ambient standard that would limit the level of formaldehyde in the home and ensure maintenance of a safe level of that chemical in the home by limiting outgassing from all sources of the chemical used in the home’s construction.  However, Section II-B-2 states that the manufactured home industry (industrial lobby) especially endorsed the use of a product standard which is precisely what HUD required, i.e., a pre-construction product standard requiring that formaldehyde emissions not exceed 0.2 parts per million (ppm) from plywood and 0.3 ppm from particleboard.  Thus, the manufactured home industry was protected from claims regarding homes that have high levels of formaldehyde.  Section II-C-1 states that “A number of consumers and academic sources stated that it was imperative that the plywood standard be lowered.”  Section II-C-2 states that “The response from consumers and several other sources on the particleboard standard was much like the response to the plywood standard.”  Also, that section states that “A few consumers felt that urea-formaldehyde-based particleboard was so significant an emitter that it should be banned from use in manufactured homes.”  However, HUD ignored these consumers and academic sources.  Section II-D states that “The Department (HUD) has concluded that an indoor ambient formaldehyde level of 0.4 ppm provides reasonable protection to manufactured home occupants.” Section II-D-2 also states that “The Department will reevaluate the formaldehyde standards when the EPA reaches a final regulatory decision and may change the standards if the basis for EPA’s finding show that these standards are not adequate to protect the health of manufactured home occupants.”  (See Exhibit A)  In 1987, EPA concluded that formaldehyde is “a probable human carcinogen”, but has taken no meaningful action since to control the hazardous substance.