Updated Draft Risk Calculation Memorandum for Formaldehyde Open for Public Comment – Update from Bergeson & Campbell, P.C.

EPA Begins Public Comment Period on Updated Draft Risk Calculation Memorandum for Formaldehyde

On December 3, 2025, the U.S. Environmental Protection Agency (EPA) announced the availability of and solicited public comment on an Updated Draft Risk Calculation Memorandum (Draft Memorandum) to inform a revised draft risk evaluation for formaldehyde under the Toxic Substances Control Act (TSCA). 90 Fed. Reg. 55726. EPA states that after further consideration of comments raised during the scientific peer review process, it is reconsidering the use of certain hazard values in the formaldehyde risk evaluation. The Federal Register notice, Draft Memorandum, and materials included in the docket provide the science and science policy basis for determining how the revised draft inhalation point of departure (POD) impacts the corresponding draft margin of exposure (MOE) estimates and the risk determination. EPA notes that although it is also providing a revised draft occupational exposure value, it “is not changing its position that formaldehyde poses unreasonable risk of injury to human health.” As such, EPA continues work on a proposed risk management rule for formaldehyde as required by TSCA to ensure statutory deadlines are met and necessary protections are not delayed. According to the notice, EPA is also seeking additional information specific to how formaldehyde is manufactured and used that may inform the risk management of formaldehyde. After public comment, EPA will determine if the proposed revisions discussed in the notice warrant updating the formaldehyde risk evaluation. Comments are due February 2, 2026. For more information, read the full memorandum.