Evaluations of Formaldehyde E missions from I nstalled L aminate Flooring and Risk to Lumber Liquidators Customers DRAFT ATTORNEYCLIENT PRIVILEGED Objective Collect representative and statistically robust data sets for ID: 648837
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Slide1
Lumber Liquidators Chinese Manufactured Laminate Flooring
Evaluations of Formaldehyde Emissions from Installed Laminate Flooring and Risk to Lumber Liquidators Customers
DRAFT
ATTORNEY-CLIENT PRIVILEGEDSlide2
Objective
Collect representative and statistically robust data sets for analysisConduct evaluations to characterize airborne formaldehyde concentrations in residences specifically from installed Lumber Liquidators (LL) Chinese manufactured laminate flooring to assess consumer riskCharacterize acute irritation risk and chronic cancer risk from formaldehyde emissions from LL
laminate flooring for its U.S. customers using standard and accepted methods
2
DRAFTSlide3
LL Evaluation Approach
3
Step
1:
Characterize formaldehyde emissions from
new
flooring
Step 4
: Characterize emission decay rate and develop
model to
estimate initial and TWA formaldehyde concentrations
in
customer residences from laminate flooring
Step
2
A
: Measure indoor formaldehyde concentrations
in residences
of LL customers
Step 2B: Survey customers to collect data on home conditions related to emissions
Step 3 Characterize emissions from installed flooring of customer residences with “elevated” badge concentrations
Step 5 Calculate residence-specific initial and TWA formaldehyde concentrations from laminate flooring and assess consumer risk from flooring emissions
DRAFTSlide4
Formaldehyde Emissions from
New Laminate Flooring Manufactured 2009-2015: Phase I Testing Results4
Parameter
LLCPSC
Sample Size (# of tests)
399
33
Mean ER (µg/m
2
/h)*
61
65
ER
= emission
rate
* No significant difference between LL and CPSC mean emission rate
DRAFTSlide5
LL Customer Population
Badge Results
31,760 badge results available from 19,316 residences >99.5% of badges have concentrations ≤0.250 ppm
Approximately
91
% had formaldehyde concentrations
≤100 µg/m
3
or ≤81ppb
(WHO
Guideline);
substantial majority were
<50
µg/m
3
or <40ppb
Approximately 9
% (~1,940 residences) had concentrations >100 µg/m3These customer residences were selected to focus further evaluations of flooring-specific contributions to residential formaldehyde concentrations
DRAFT5Slide6
Survey of Phase II Participants
~1,660 completed surveys as of March (out of ~2,900 residences)subset including reported
laminate-board measure: n = 899* Age of Residences*Representative air exchange rate (AER) derived from age of residence≤20 years old (44%)
(assumed AER
= 0.329
;
Persily
et al. 2010
)
>
20 years old
(56%)
(assumed
AER = 0.621
; conditional on ≤20-yr data)
Area of laminate flooring in each residence*
Floor area of residence from survey and area of flooring purchased from customer records
Combined to estimate residence-specific Flaminate (fraction of total floor area covered with laminate)Mean Flaminate = 0.4585.8% Flaminate = 1 (100% coverage)6
DRAFTSlide7
Profile of LL U.S. Laminate Customer Population (for Comparison)
7
California customers who installed LL Chinese laminate flooring between 2011 and 2015 based on Experian data, as surrogate for U.S. customers
Age of residence
Based on age of home
25%
residences constructed after 1990 with possible “tight” construction)
75%
residences constructed in decades before 1990
Fraction of floor area as LL laminate
Mean
F
laminate
= 0.32
79% of customers have
F
laminate
≤0.50
0.02%
have Flaminate of 1.0 (100% coverage)DRAFTSlide8
Greater Phase I Emission
Rates Indicate Decay of Formaldehyde Concentrations Over Time
DRAFT
8Slide9
Decay
Pattern Estimated from Combined Phase I and Phase II Test Results
NOTES:
biexp
(p, k1, k2) = p
exp
(–k1 t) + (1–p)
exp
(–k2 t)
Blue parameter values are those of the Bogen (2015) fit to Zinn et al. (1990) data
The biexp fit is significantly better than the Zinn-fit-conditioned fit
DRAFT9Slide10
Current Residential Formaldehyde
Concentrations for Phase II Customers
899 emission rates from Phase II testingAll residences have estimated current flooring-related formaldehyde concentrations <90
µg/
m
3
; 99.9% are <35 µg/m
3
Mean flooring-related current formaldehyde concentration =
5.2
µg/m
3
10
DRAFTSlide11
Initial Formaldehyde Concentration
from Laminate Flooring in
Residences with Elevated Badge Concentrations Based on Residence-Specific Phase II Emissions Data
(
n
=
899)
Initial
Formaldehyde Concentration (µg/m
3
), unadjusted for residential occupancy
Residence
duration
Selected Percentile
and
Mean Concentrations in Residences(years)Fdecay
Foccup510
2550
Mean
75
90
95
0
1.0000
1.0000
2.12
3.72
8.85
18.4
23.3
30.2
48.5
66.1
DRAFT
11Slide12
TWA Formaldehyde Concentrations (
CTWA
) from Laminate Flooring in
Residences with Elevated Badge Concentrations Based on Residence-Specific Phase
II Emissions Data
(
n
=
899)
TWA Formaldehyde Concentration (µg/m
3
), unadjusted for residential
occupancy
Residence duration
Selected Percentile
and
Mean
Concentrations
in Residences(years)
FdecayFoccup5102550
Mean759095
2
0.3363
1.0000
0.71
1.25
2.98
6.19
7.84
10.2
16.3
22.2
12
0.2262
1.0000
0.48
0.84
2.00
4.16
5.27
6.83
11.0
14.9
20
0.1862
1.0000
0.39
0.69
1.65
3.42
4.34
5.62
9.03
12.3
26
0.1633
1.0000
0.35
0.61
1.44
3.00
3.804.937.9210.8
2 years is the exposure duration used in the ATSDR assessment12 years is the average duration of residency in the U.S. (U.S. EPA Exposure Factors Handbook)20 years is the expected use life of laminate flooring26 years is the 90th percentile duration of residency in the U.S. (U.S. EPA Exposure Factors Handbook)
DRAFT
12Slide13
Predicted TWA Formaldehyde Dose from Laminate Flooring in all Residences with Phase II Emissions Data (
n = 899)
Residence
Time(years)
Median
daily dose
(µg/day)
Mean
daily dose
(µg/day)
12
8.
5
11
20
1
21526
1317DRAFT13Note: Proposition 65 safe harbor dose is 40 µg/daySlide14
Conclusions
Installed LL Chinese manufactured laminate
flooring poses neither a significant acute irritation risk nor chronic cancer risk to customersSubstantial sampling, testing and risk assessments have been performed to characterize formaldehyde in residences with installed LL Chinese manufactured laminate flooringOnly ~9% of the ~ 20,000 residences with LL laminate flooring samples had total formaldehyde concentrations from all sources >100 µg/m
3, the WHO
Guideline
None of the residences with elevated badge concentrations currently has a formaldehyde concentration from flooring >100
µg/m
3
Only 6 out of 899 of the residences with elevated badge concentrations are estimated to have had initial formaldehyde concentrations
>100
µg/m
3
(<1%)
Rate of formaldehyde emissions and in-residence concentrations diminish by >3-fold within one year of installation and continue to diminish slowly thereafter
Estimated median and mean daily formaldehyde doses from laminate flooring for customers in residences with elevated badge concentrations are below the Proposition 65 safe harbor level of 40 µg/day for formaldehyde as a carcinogen
Based on the U.S. EPA cancer model,
average and upper bound TWA exposures from laminate flooring for the 9% of customer with residences with elevated badge concentrations are expected to pose cancer risks of <1 to 3 in 100,000
The vast majority of LL laminate customers have cancer risks <1 in 1,000,000 from LL Chinese manufactured laminate flooring14DRAFT