NOTE: The following is one of a series of case studies produced by the Union of Concerned Scientists' Scientific Integrity Program between 2004 and 2010 to document the abuses highlighted in our 2004 report, Scientific Integrity in Policy Making.
Updated on: Dec 19, 2007
Despite warnings that some travel trailers and mobile homes provided to Katrina disaster victims contained harmful levels of formaldehyde, the Federal Emergency Management Agency (FEMA) failed to adequately test occupied trailers and did not determine how many of the tens of thousands of trailer residents might be in danger.
Internal FEMA documents obtained by the House Committee on Oversight and Governmental Reform show that FEMA, with the help of other government agencies, developed a formaldehyde testing procedure inapplicable to the real conditions in FEMA trailers,1 had the data analyzed using inappropriate safety thresholds for long term exposures,2 and did the bare minimum to inform trailer residents about the dangers of formaldehyde.3 FEMA appears to have developed a policy response intended to dodge liability,4 public outrage, and negative media.5
FEMA provided 120,000 mobile homes and travel trailers to Gulf Coast residents, but has no idea how many formaldehyde complaints they have received.6 By not using the best available scientific information to protect the health of these displaced Gulf Coast residents, FEMA failed to faithfully execute its mission of emergency recovery and mitigation.7
The first report of formaldehyde problems in trailers came from the Stewart family in southern Mississippi, who contacted their local TV station in March 20068 after independent testing showed their constant respiratory ailments were likely due to high levels of formaldehyde. Despite following the FEMA instructions for airing out their trailer, they constantly suffered from runny or bloody noses, burning eyes, scratchy throat, difficulty breathing, and coughing.9
These complaints are all common symptoms of exposure to formaldehyde, a toxic gas which is also a carcinogen.10 Formaldehyde is commonly released into the air from particleboard, plywood, glues and adhesives, permanent press fabrics, and some types of insulation.11
Alarmed by the Stewart's experience, the Sierra Club initiated its own testing of occupied FEMA trailers. In April 2006, they reported that 83% of the 52 trailers they tested12 had formaldehyde levels above the threshold* the Environmental Protection Agency (EPA) warns can cause acute health effects.13 FEMA tested one occupied trailer in April 2006, and the formaldehyde levels registered at twelve times the EPA's value;14 this is the only occupied trailer test ever conducted by FEMA prior to the onset of congressional oversight over a year later.
FEMA internal documents are peppered with anecdotal cases of formaldehyde complaints, including: a mother scared to pursue the issue too far for fear of losing her trailer;15 a man with non-Hodgkins lymphoma who couldn't breathe in his trailer and was told by FEMA to "contact local charitable organizations" to find an alternate place to live;16 and a man who died in his trailer who had told his neighbor he was "afraid to use his A/C because he was afraid it would make the formaldehyde worse."17
Between April and May 2006, FEMA headquarters continued to insist that ventilation was the only step necessary to remove formaldehyde from occupied trailers,18 while the FEMA Office of General Counsel (OGC) opposed any direct testing of the occupied travel trailers.19
As one OGC employee said, "Do not initiate any testing until we give the OK. While I agree that we should conduct testing, we should not do so until we are fully prepared to respond to the results. Once you get results and should they indicate some problem, the clock is ticking on our duty to respond to them."20 Another email repeats these concerns, reading "OGC has advised that we do not do testing, which would imply FEMA's ownership of the issue."21
These concerns were echoed again in the inter-agency meeting between FEMA, the Environmental Protection Agency (EPA), and the Centers for Disease Control and Prevention (CDC).22 In a call on July 11, 2006, senior EPA officials advised FEMA that the "health base level" for formaldehyde might be much lower than previously expected,* and they were concerned about "the advisability of testing at all."23 Using the appropriate exposure threshold for lengthy exposures, EPA officials warned FEMA that "the levels we find after testing [occupied trailers] may well be more than 100 times higher."24
Despite this information that it was likely trailer residents were exposed to dangerous levels of formaldehyde, FEMA issued a brochure25 in July repeating that idea that ventilation was sufficient to reduce formaldehyde levels. The brochure did not include contact information for complaints,26 and the health information on the brochure is also far from complete. Notably it does not mention that negative health effects of formaldehyde can occur at levels below which the chemical can be smelled.27
Instead of leaving the July 11 phone call with a comprehensive plan of action to scientifically test occupied trailers and then remove hurricane victims from contaminated units, the FEMA and EPA senior leadership agreed instead to test ventilation methods on unoccupied trailers. 28 This testing methodology completely failed to simulate the living conditions of a trailer resident,29 so results, which would not be released for another eight months, 30 were useless for determining a policy to protect trailer residents.
The plan, which "everybody seemed to like,"31 was to seal unoccupied trailers for 2 weeks and then ventilate them by either by running the air conditioner or opening the windows for the following two weeks.32 Daily measurements would determine if ventilation could lower the internal formaldehyde concentrations to acceptable levels.33
This testing methodology did not simulate the living conditions, temperatures, humidities, standard ventilation practices, or timescales at which residents lived in the trailers. It also did not take into account that the trailer building materials continue to emit formaldehyde for four to five years.34
Instead of being concerned about the limitations of their testing design, FEMA worried about how they could keep the final information from reflecting negatively upon them. As seen from the July 2006 meeting, officials were concerned that "it will be almost impossible to not ... release testing results to the public" and "the media will characterize any findings in the worst possible light."35
Fudging the data
The final data, already fundamentally flawed due to the design of the trailer testing, was obscured even further by the skewed analysis performed by the Agency for Toxic Substances and Disease Registry (ATSDR), a part of the Department of Health and Human Services.36
ATSDR has established exposure levels for determining safe exposures to formaldehyde.* Rather than these values, they inexplicably set a "level of concern" for "sensitive individuals" to a value 10 times higher than their recommendation for exposures under a year, and almost 38 times higher than the recommendation for exposures over a year.
Even using this "level of concern," the analysis showed that ventilation with air conditioning was insufficient to lower the formaldehyde level in the trailers until the very last day of measurement. Ventilation with open windows and vents fared slightly better, staying below the "level of concern" after the first five days of testing. However, only one measurement out of both ventilation methods ever dropped below the original limit for less than a year of exposure.37
In testimony before Congress, independent industrial hygienist Mary DeVany described the FEMA testing and analysis process by saying "All I can say, in my professional opinion, is that they did this in order to minimize the actual extent of the problems in these trailers. I have no other conclusion I can draw… I think it was a complete violation of our professional code of ethics."38
In the face of congressional oversight by the House Committee on Oversight and Governmental Reform, FEMA stonewalled for a year by claiming attorney-client privilege for thousands of documents.39 Finally, after a July 19, 2007 hearing, the agency announced a new round of testing, this time of occupied trailers for a variety of air quality contaminants.40
ATSDR has also retreated from its earlier data analysis. Three months after the hearing, ATSDR released a new version of its health consultation, saying the first report "contained insufficient discussion of the health implications of formaldehyde exposure."41 This revised report states that the data and analysis "cannot be used to predict the health consequences of living in .. trailers," says the testing was never intended to represent living conditions, and retracts the use of the health "level of concern."42
According to July 2007 testimony from Administrator Paulison, FEMA has only replaced 58 travel trailer units because of formaldehyde concerns.43 Tragically, 69,194 units were still occupied as of August 25, 2007.44
FEMA is not a federal science agency, but that does not recuse it from acting upon the best available science to protect the health of disaster victims. FEMA ignored a cacophony of warnings and condoned testing and data analysis that was virtually irrelevant. While the agency is moving towards proper testing now, the year long delay in action has exposed already disadvantaged citizens to unnecessary health risks.
*While federal standards exist for formaldehyde content in some building materials45 or in workplace exposures46, there is no federal standard regulating indoor air quality. However, EPA and the Agency for Toxic Substances and Disease Registry have suggested values for safe exposure, which are reproduced below along with some of the formaldehyde measurements referenced in this article. It is important to keep in mind that FEMA trailers are intended to be occupied for up to a year and a half by evacuees.47
|EPA recognized level at which acute health effects can manifest48||0.1 parts per million (ppm)|
|Agency for Toxic Substances and Disease Registry Minimum Risk Levels (MRL)49>||0.04 ppm - short exposures up to 14 days|
|0.03 ppm – exposure durations between two weeks and a year|
|0.008 ppm – exposures exceeding 365 days|
Other Relevant Data
|Stewart family trailer50||0.22 ppm|
|FEMA occupied trailer test (April 6, 2006)51||1.2 ppm|
|Formaldehyde odor threshold52||0.5 – 1.0 ppm|
|Formaldehyde levels detected in the unoccupied trailer testing on the 14th (last) day of testing using air conditioning ventilation53|| Lowest: 0.004 ppm
Highest: 0.48 ppm
|Formaldehyde levels detected in the unoccupied trailer testing on the 14th (last) day of testing using open window ventilation54|| Lowest: 0.003 ppm
Highest: 0.08 ppm
Note: The full set of FOIA documents from the July 19, 2007 House Committee on Oversight and Government Reform hearing are no longer available on the House Oversight Committee's website. Selections used in this article are individually linked in the footnotes.
1. Hearing on FEMA's Toxic Trailers. Committee on Oversight and Government Reform. July 19, 2007. From FOIA documents released to the public, which will hereafter be referred to by naming convention used on the Committee's website. Exhibit R, Supplemental C. See also the original Health Consultation: Formaldehyde Sampling at FEMA Temporary Housing Units. Agency for Toxic Substances and Disease Registry. (hereafter original ATSDR Health Consultation). Feb 1, 2007.
2. Written Testimony of Mary DeVany before the House Committee on Oversight and Governmental Reform. July 19, 2007. See also the original ATSDR Health Consultation.
3. Exhibit U and Exhibit T.
4. Exhibit S and Supplemental A.
5. Exhibit R.
6. Written testimony of R. David Paulison, Administrator of FEMA, before the House Committee on Oversight and Governmental Reform. July 19, 2007.
7. Federal Emergency Management Agency. About FEMA webpage. Accessed Dec 18, 2007.
8. Couple discovers high levels of formaldehyde in FEMA trailer, WLOX, Mar 17 2006.
9. Written Testimony of Paul Stewart before the House Committee on Oversight and Governmental Reform. July 19, 2007.
10. ATSDR. Toxicological Profile for Formaldehyde. Accessed Dec 18, 2007.
11. ATSDR. Toxicological Profile for Formaldehyde.
12. Sierra Club. Toxic Trailers? Accessed Dec 18, 2007.
13. Environmental Protection Agency. Basic Information: Formaldehyde. Accessed Dec 18, 2007.
14. Exhibit B
15. Exhibit E
16. Exhibit I
17. Exhibit M
18. Exhibit G
19. Exhibit D
20. Supplemental A
21. Supplemental B
22. Exhibit R
23. Exhibit R
24. Exhibit R
25. Exhibit U
26. Exhibit T
27. Original ATSDR Health Consultation
28. Exhibit R
29. Exhibit R
30. Original ATSDR Health Consultation
31. Exhibit R
32. Original ATSDR Health Consultation
33. Exhibit R
34. National Library of Medicine. Hazardous Substances Data Band (HSDB) for Formaldehyde. 2006.
35. Exhibit R
36. Exhibit D
37. Original ATSDR Health Consultation
38. Oral testimony of Mary DeVany Stewart before the House Committee on Oversight and Governmental Reform. July 19, 2007. Pages 107 and 108 of the full hearing transcript.
39. Full supplemental memo, prepared by the House Committee on Oversight and Government Reform for the July 19, 2007 hearing.
40. FEMA. Formaldehyde and Travel Trailers. July 20, 2007. Accessed Dec 18, 2007.
41. ATSDR. An Update and Revision of ATSDR's February 2007 Health Consulation: Formaldehyde Sampling of FEMA Temporary-Housing Trailers. Oct 2007. Accessed Dec 18, 2007.
42. ATSDR. An Update and Revision of ATSDR's February 2007 Health Consulation.
43. Written testimony of Administrator Paulison.
44. FEMA. Katrina and Rita: Direct and Financial Housing Assistance Breakdown as of 08/25/07. Accessed Dec 18, 2007.
45. 24 CFR 3280.308
46. 47. FEMA. Disaster Assistance Frequently Asked Questions. Accessed Dec 18, 2007.
48. EPA. Basic Information: Formaldehyde.
49. ATSDR. Minimal Risk Levels for Hazardous substances. Accessed Dec 18, 2007.
50. Written Testimony of Paul Stewart.
51. Exhibit B.
52. Original ATSDR Health Consultation.
53. Original ATSDR Health Consultation.