Wednesday, December 7, 2011

S&S Company Review/Comments on the Field Test Result

DTSC Provided a copy of its Formaldehyde Treatment Technologies Re-Certification Evaluation
Report to S&S Company and American BioSafety for their comments. At S&S Company’s request,
DTSC extended the review/comment period an additional 90 days for S&S Company to determine the
cause of the increased toxicity. On May 29, 2001, S&S Company of Georgia, Inc. submitted data
from analyses performed by Sequoia Analytical (Sequoia), a company with a group of analytical
laboratories in California. The Sequoia submittal did not comment directly on the DTSC field tests. An
initial review of the Sequoia data package by DTSC staff identified critical problems with the Sequoia
data set. On July 16, 2001, American Bio-Safety, Inc., the California distributor of Formalex,submitted a letter via e-mail acknowledging data quality problems with the Sequoia data package.
The reasons for increased toxicity after treatment with Formalex when tested using the standard
bioassay procedure (which includes an extended shaking period) are still unknown. The design of the
Sequoia Analytical work did not provide any information that may explain the high toxicity results
determined during the DTSC field tests

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