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Risk Management


Based on the risk characterisation for the environment, general public and workers (Chapter 17), risk to human health is the major concern from exposure to formaldehyde. The critical human health effects are sensory irritation, skin sensitisation and carcinogenicity. The main public health risks are for sensory irritation in situations of high indoor air formaldehyde levels, such as mobile homes and relocatable buildings. The general public is also at risk of skin sensitisation by using numerous types of consumer products containing formaldehyde such as cosmetics. Occupational health risks for sensory irritation exist in some industries using high concentrations of formaldehyde products, such as embalming in funeral homes and pathology laboratories.
To minimise these risks, this chapter discusses current risk management controls and practices and identifies further actions that are needed for protecting the environment, general public and workers from exposure to formaldehyde. The further actions, together with information on relevant overseas risk management practices, assisted in formulating the recommendations, which are discussed in the Overview and Recommendations section of this report.


    1. Environmental risk management

The major anthropogenic release of formaldehyde in Australia is into the atmosphere, primarily as a result of fuel combustion processes. Therefore, this section focuses on ambient air quality controls.



      1. Current ambient air quality controls

Regulatory controls for hazardous air pollutants vary between countries. The most common regulatory controls employed worldwide include the setting of emission standards for stationary and mobile point sources of air pollution, overall emission reduction goals, national ambient air quality standards, action programmes targeting individual pollutants or specific environmental problems, and land-use regulations which can control the geographical areas in which air pollution sources (such as industries) can be situated. Many countries have established lists of priority air pollutants, however, only a few countries have set national ambient air quality standards for individual hazardous pollutants.



Australia


Air quality initiatives
The Australian Government Department of the Environment and Heritage (DEH) is currently implementing national policies and programs to reduce emissions from the transport, industry and residential sectors. National initiatives to reduce the impact of road transport on air quality include improving the emission performance of the Australian vehicle fleet by implementing fuel quality standards (see below), reducing in-service vehicle emissions, encouraging fuel efficient and environmentally friendly vehicles and technologies, and promoting use of alternative fuels. For industry, specific codes of practice are being
developed for spray painters/surface coaters, printers and dry cleaners to reduce evaporative emissions through the promotion and adoption of vapour recovery practices and techniques. DEH is also undertaking a number of initiatives designed to reduce wood smoke emissions. This work includes community education on the correct operating practices for wood heaters, seeking improvements to wood heater installation and emission standards, and sponsoring research to improve understanding of wood heater emissions.
A forecasting system, the Australian Air Quality Forecasting System (AAQFS), is being developed which predicts daily levels of photochemical smog, atmospheric particles and a range of other pollutants. Components of the model generate air quality forecasts for 25 pollutants (including formaldehyde) in urban and non- urban areas. This information will enable environment protection agencies and industry to test effectiveness of strategies to reduce air pollution and raise awareness of air quality as an environmental issue. EPA Victoria is providing methods for use by major Australian cities to calculate daily pollution emissions. The Bureau of Meteorology generates the high-resolution weather forecasts and CSIRO has created computer models to calculate pollution levels.
State and territory governments are undertaking similar initiatives to improve air quality by reducing emissions from a range of sources.
Ambient air quality management
Currently, there is no national ambient air standard for formaldehyde. The National Environmental Protection Council (NEPC), a statutory entity within the Environmental Protection and Heritage Council, sets national environmental objectives through the development of National Environment Protection Measures (NEPM). NEPM can comprise any combination of goals, standards, protocols or guidelines, which are then implemented in all Australian jurisdictions.
A NEPM for Air Toxics was proposed by the National Environment Protection Council (NEPC) in 2001, and was endorsed in April 2004 (NEPC, 2004). Air toxics include gaseous, aerosol or particulate pollutants that are present in the air in low concentrations, with characteristics such as toxicity or persistence, so as to constitute a hazard to human, plant or animal life. Formaldehyde is one of five priority hazardous air pollutants addressed in the NEPM.
The goal of the NEPM is “to improve the information base on ambient air toxics within Australia in order to facilitate the development of standards following a review of the NEPM within eight years of its making”. The stated objectives are to:


        • facilitate collection of monitoring data for ambient air toxics in order to inform future risk assessments and the development of standards;




        • establish a set of investigation levels which can be applied nationally to the five priority air toxics as benchmarks against which the quality of ambient air can be assessed; and




        • establish nationally agreed methodologies for determining appropriate locations for air monitoring these air toxics, conducting monitoring, and reporting results of monitoring.

The NEPM includes investigation levels that will be incorporated into a guideline. These levels are intended to assist jurisdictions in the interpretation of monitoring data and to evaluate the nature and extent of any risk to health of the communities in the areas of the monitoring sites. The ‘investigation level’ set for formaldehyde in this NEPM is 40 ppb over an averaging period of 24 hours (NEPC, 2004).


Generally, state and territory governments manage ambient air quality through regulations relating to environmental protection, air quality improvement and/or pollution reduction policies. Examples of strategies include setting specific industrial emission limits, implementation of standards and codes of best practice for industrial processes, use of licence fees based on pollutant loads produced, land-use regulation, standards on emissions from solid fuel stoves and heaters and local planning approval requirement for installation of such appliances, vehicle emission testing, policies on reduced vehicle use, alternative fuel use policies, environmental tobacco smoke regulation, and bush clearing regulation.
An example of state ambient air quality management is the Victorian legal framework for protecting air quality by the Environment Protection Act 1970, which provides for the development of state environment protection policies (SEPPs). Two SEPPs regulate air quality: SEPP (Ambient Air Quality) and SEPP (Air Quality Management). Under the latter, industries are required to control emissions of pollutants by best available practices to achieve policy aims that include consideration of economic, social and environment issues in the management of emissions to the air environment (Victorian Government, 2001).
The SEPP sets two types of criteria for the assessment of emissions to the air environment – ‘design criteria’ and ‘intervention levels’. Design criteria are modelling tools to assess residual emissions from individual industrial premises after emission controls have been applied. They are used in the design stage of a facility and are not used for monitoring purposes. Intervention levels are applied to individual pollutants in relation to neighbourhood air quality and take into account cumulative sources of a pollutant within a local area (or neighbourhood). They are used with air monitoring data to assess whether air quality within a neighbourhood is acceptable, acting as triggers for possible further actions if the level is exceeded. Formaldehyde has a design criteria set at 40 g/m3 over a 3- minute averaging time, and an intervention level set at 15 g/m3 over a 1-hour averaging time. The intervention levels are risk-based levels adopted from the Texas Natural Resource Conservation Commission (TNRCC) Effects Screening Levels (EPA Victoria, 2001a, 2001b).
Another example of state ambient air quality management is in Western Australia (WA). With the aim of protection of human health and the environment, the Department of Environmental Protection and the Health Department of WA have embarked on a joint program to develop ambient air quality guidelines and guideline values for air contaminants of concern, with the overall objective of providing a framework and benchmark for the assessment and management of air contaminants in WA. As an interim approach for substances not listed in the NEPM for ambient air, WA adopts WHO guideline values (see below), with appropriate amendments to suit the WA context. Where there is no NEPM or WHO guideline, criteria from another jurisdiction will be adopted, once it has been assessed and determined to be applicable to the WA context (DEP, 2003).



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