MEMORANDUM
TO: 		Formaldehyde Work Group
FROM:	Rebecca Edelstein, EPA/OPPT/EETD
DATE:	February 23, 2011
SUBJECT:	List of Urea-Formaldehyde Resin Substitutes

The purpose of this document is to identify chemicals that should be assessed for hazard and exposure based on publicly available information and input from public meetings, the California Air Resource Board (CARB), and ANPR comments on potential substitutes.  Stakeholders from industry as well as CARB have stated that the CARB Air Toxics Control Measure (ATCM) is technology forcing; therefore, new technologies will likely be developed in the next few years that are not discussed in this document.  
  
The type of resin used to manufacture pressed wood products greatly affects the amount of formaldehyde released.  Therefore, most technologies designed to limit formaldehyde emissions focus on alternative resins.  Different resins that are expected to be used to limit the emissions of formaldehyde from the three pressed-wood products regulated under the CARB ATCM are listed below: 

   Hardwood Plywood (HWPW) 
         * Urea-formaldehyde (UF) + Melamine (1,3,5-triazine-2,4,6-triamine)
         * Polyvinyl Acetate (PVA)
         * PVA-Soy
         * Phenol-formaldehyde (PF)
         * Polyamide-soy -- based on the combination of a polyamide epichlorohydrin combined with soy flour

   Particleboard (PB) 
         * Urea-formaldehyde (UF) + Melamine 
         * Urea-formaldehyde (UF) + Scavengers
         * Phenol-formaldehyde (PF)
         * Melamine-Formaldehyde (MF) + Scavengers
         * Cashew nut shell liquid resin 
   
   Medium Density Fiberboard (MDF) 
         * Urea-formaldehyde (UF) + Melamine
         * Urea-formaldehyde (UF) + Scavengers
         * Polymethylene diphenyl diisocyanate (pMDI)
         * Melamine-Formaldehyde (MF) + Scavengers

Likely scavengers, additives, and cross linking agents that may be added to the resins include: urea, ammonia, phenol, tannins, soy protein (hydrolysates and meal), melamine, hexamethylene tetraamine (commonly referred to as hexamine), sodium sulfate, sodium chloride, triacetin (glycerol triacetate), tris(hydroxymethyl) nitromethane, and chromium complexes.

Public comments from members of the pressed wood industry indicate that these substitutes have a number of limitations (both cost and performance), but that the industry is committed to meeting the CARB ATCM phase 2 limits and is working on resolving the cost and performance issues.  Information provided by CARB in a teleconference (July 29, 2009) and on its website on approved no added formaldehyde (NAF) and ultra-low emitting formaldehyde (ULEF) resins indicates that the alternative resins and scavengers listed above are consistent with what industry is currently using in certain products to meet the CARB ATCM limits.  

                                       
                                       

