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Probable routes of human exposure from the operation include (1) inhalation of wood fibers, (2)inhalation of gaseous formaldehyde, and (3) inhalation of wood fibers impregnated withformaldehyde. Another potential exposure would be from dermal contact with HCHO containingwood fibers and, to a lesser extent, gaseous HCHO. The facility hired an outside health consultantgroup to conduct an occupational health survey of 39 employees (24% of the total work force)during 1995. Only one of the employees reported a condition that might be related to theseexposure pathways. That individual's health complaint was sinusitis. The conclusion of theconsulting group was that there was no demonstrated pattern of adverse health occurrence norrelated illness/injury at the plant resulting from occupational exposure. The opinion of the groupwas supported by the Occupational Safety and Health Administration (OSHA) 200 report of1994. The OSHA 200 report is a list of injuries or accidents that occurred in the workplan duringthe year. The 200 report listed three injuries for 1994, all of which were extremity injuries. Theplant's annual absenteeism rate of 0.69% was below the national average of 3.1%.

The United States Environmental Protection Agency (USEPA) regulates the amount, size, andtime frame for the release of particulates from a site using the National Ambient Air QualityStandard (NAAQS). Under the NAAQS, the PM10 standard is 150 micrograms per cubic meterfor a 24-hour period, and 50 micrograms per cubic meter of air for an annual standard. Recent airsampling and modeling carried out by a Willamette consultant in the Gifford community (which iswithin 2,000 meters of the facility) found that neither of the standards were exceeded. The highest24-hour air particulate concentration was 60.16 micrograms per cubic meter of air. Modeling todetermine worst case scenarios for the annual PM10 by the consultant predicted thatconcentrations would not exceed 5 micrograms particulate per cubic meter of air. This is belowthe annual standard. Ambient air monitoring conducted during 1993 and 1994 by ADPC&E,under the guidelines governing acceptable level of atmospheric release of particulate matter, neverfound the company to exceed the level of the acceptable monthly average of 5.25 grams persquare meter.

Sampling conducted outside the home of one of the primary complainants by ADPC&E during1993 and 1994 failed to detect formaldehyde levels of concern. Indoor sampling conducted by theADH during this same time period were higher than the levels found outside by ADPC&E. Asimilar outdoor/indoor sampling strategy was conducted by an independent consultant in 1996,and the same pattern of formaldehyde levels was revealed. Higher levels of formaldehyde werenoted indoors than outdoors. Once again, the outside levels were less than any level of concerncited in the scientific literature.

Table 1.

HCHO Levels Indoors and Outdoors
Date Sampled Indoor Concentration
Outdoor Concentration
11/17/94 10.4 5.18
3/21/96 27.6 0.79

Consultants for the residents estimated that 2% of the wood fibers were comprised of HCHO. The highest amount of HCHO exposure that could be extrapolated from the consultant'sassumptions was 0.002 parts per million (ppm). ADPC&E collected wood fibers from a residentwithin a mile of the plant. ADPC&E's data indicated that, for each particle of wood fiber in theair, only 1/1,000,000th of that particle is formaldehyde. Irritant effects have been reported atHCHO levels ranging from 0.1 to 3 ppm, and concentrations as low as 0.03 ppm have beenreported to impact sensitive individuals. The World Health Organization (WHO) Working Groupon Assessment and Monitoring of Exposure to Indoor Air Pollutants (1983) found that indoorHCHO concentrations of less than 0.05 ppm were of limited or no concern and concentrationsabove 0.10 ppm were significant enough to call for corrective action in an indoor scenario.

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