Written by Goo Lee, APA Certifications Operations Manager

Oriented strand board (OSB) plays a significant role in the housing sector, with applications including sheathing, cladding, furniture and paneling. OSB is a type of wood structural panel manufactured from wood strands that are consolidated in a cross-oriented manner and bonded with water-resistant thermoset adhesives. OSB offers superior durability and is relatively consistent and dense. It is mainly used in construction for structural purposes like wall sheathing, floor and roof systems.

OSB is projected to play a major role in the construction industry’s recovery from the lingering effects of the COVID-19 pandemic. According to Mordor Intelligence, OSB is popular due to its staunch and useful properties, and cost-effectiveness. An April 2024 market report states that the global market for OSB, estimated at US $21.7 billion in 2023, is projected to reach US $50.6 billion by 2030.

Adhesives play a crucial role in producing this important construction material. The impending Environmental Protection Agency (EPA) regulations will impact the OSB manufacturing, particularly the proposed risk evaluation for formaldehyde under the Toxic Substances Control Act (TSCA).

We are very concerned that we will not be able to make wood products in the U.S. should the EPA put forward an occupational exposure value (OEV) of 11 parts per billion (ppb), which is well below indoor background levels. It also fails to reflect the standards of review set by TSCA for use of the best available science.

The adhesives, which may contain small amounts of formaldehyde used to make the OSB products, are a critical component to comply with the performance required by applicable national standards such as Performance Standard (PS) 2-18 and building codes. The availability of these versatile and cost-effective wood products would be significantly impacted by the TSCA rule. The extremely low proposed OEV for formaldehyde in the draft TSCA evaluation is below naturally occurring background levels and way below ambient concentrations routinely found in indoor environments.

Given the impact it could have on our industry — as well as a host of other industries — it is important to take the time to get it right. APA members are very interested in the TSCA risk evaluation and the potential impact its conclusions could have on the use of adhesives to make these engineered wood products.

To continue making engineered wood products in this country — which should be a no-brainer, given the host of positive benefits this industry provides to our citizens and the environment — there needs to be a serious and extensive review of the proposed OEV 11 ppb standard at this stage in the TSCA process. It is imperative to get it right. We therefore ask for an examination of the European Union’s derivation of 300 ppb as its OEV and how that can and should inform the EPA’s recommended OEV, as well as a critical review of the study used in support of the 11 ppb proposal.

Formaldehyde is one of the most comprehensively studied and regulated chemicals in the world. Any evaluation of formaldehyde must start with the most reliable scientific evidence and the undeniable truth that formaldehyde is a natural component of the environment, which has become vital to sustainable engineered wood products like OSB.

If additional restrictions were put in place, it would not only impact the production of OSB, but dozens of other materials in the construction industry, like roofing shingles and insulation.