New Formaldehyde Regulations Weeks Away
The world's strictest formaldehyde emission standards for composite wood products take effect in California in just a few weeks, starting Jan. 1, 2009. That means particleboard, medium density fiberboard (MDF) and hardwood plywood manufactured for sale or use in California must comply with the new California Air Resources Board (CARB) regulations.
Countdown to CARB, brought to you by panel producers Timber Products Company and SierraPine, provides you with the information you need to know to get ready for the new CARB regulations. This fourth issue looks at late breaking developments as we near the deadline, new labeling information, and the potential spread of formaldehyde regulations across the country.
To read the previous three issues of Countdown to CARB, click here:
For more information or for specific CARB-certified material questions, contact info@timberproducts.com or info@sierrapine.com.
CARB Going National? The EPA Might Have a Say
California's new formaldehyde regulations are getting national attention. Several other states, and the Environmental Protection Agency (EPA), are studying the CARB regulation, meaning this issue is now on the radar beyond California's borders.
In late November, the EPA issued an advance notice of proposed rulemaking (ANPR) that describes its initial steps to investigate potential actions, and take public comments relating to formaldehyde emissions from composite panel wood products. The agency said it will develop risk assessments, evaluate costs and benefits of possible control technologies and approaches, and determine whether EPA action is needed to address any identified risks. Public comment will be taken for 60 days from the date of the ANPR's issue.
Read the full EPA Advance Notice here: http://www.epa.gov/opptintr/chemtest/formaldehyde/index.htm
Retroactive Certification Still Questioned
Since CARB issued an advisory last month that allows wood panels produced before a mill was third-party compliant to be retroactively certified, questions have been raised from distributors about this issue. Basically, what the advisory means is those panels currently in inventory or already in the distribution pipeline, made before the date of CARB certification, can be labeled as CARB-certified if they came from a mill that has its third party certification and can demonstrate that those panels meet the Phase I emission levels.
CARB recognizes that some of these composite wood products emit formaldehyde at levels below the Phase I emission standards. Those products that were produced before the mill was CARB-certified may be retroactively certified using the "non-complying lots" provision in the airborne toxic control measure (ATCM).
CARB has posted the regulatory advisory on its Web site at http://www.arb.ca.gov/toxics/compwood/compwood.htm.
Labeling Help on the Way
As reported in Countdown to CARB Issue #2, distributors are still wondering how best to manage the cumbersome labeling processes mandated under CARB. In a new development, CARB issued an advisory on Dec. 5 that spells out modifications and clarifications of labeling rules for manufacturers, distributors, importers, retailers and fabricators. Thoroughly reviewing the advisory is the best way to understand what you will need to do to be in compliance.
CARB posted its labeling advisory here: http://www.arb.ca.gov/toxics/compwood/outreach/labelingadv.pdf
Phase II Products Coming Soon
Allowable formaldehyde emissions of California's CARB Phase II emission levels are about half the amount required by Phase I. Fortunately, while Phase I requirements take effect Jan. 1, 2009, companies have some time to figure out how to meet Phase II levels. For hardwood plywood, Phase II becomes effective Jan. 1, 2010. Particleboard and MDF have an additional year to comply with this final phase.
To make the transition to Phase II products as smooth as possible, Timber Products Company and SierraPine are aiming to introduce Phase II-certified panels well ahead of the next deadline. In fact, depending on the product line, Phase II certified products are already available to the market. Other products will be introduced mid-year 2009 providing you options on sourcing products that meet the lowest CARB emission limits. This will also make the Phase II sell-through provisions a non-issue as companies start gearing up for implementation of this final phase.
SierraPine Receives CARB NAF Exemption
SierraPine received the first NAF Exemption Executive Order issued by the California Air Resources Board on Dec. 5, 2008. This exemption recognizes SierraPine's leadership in producing sustainable medium density fiberboard products with a no added formaldehyde resin system.
This exemption is different than the ULEF exemption and was granted in part because of the extremely low formaldehyde emissions of SierraPine's SDF product line – as low as 0.01 ppm and even lower. While the Executive Order significantly reduces the testing requirements, products in this category must still follow strict labeling requirements.
See the NAF and ULEF exemption here:
http://www.arb.ca.gov/toxics/compwood/naf_ulef/naf_ulef.htm
CARB Certified Mills Posted Online
CARB has updated the list of domestic and international mills that have been identified by an authorized third party certifier as producing CARB compliant materials. Find the list here: http://www.arb.ca.gov/toxics/compwood/tpc/listofmills.htm
Previous Versions Online
To read the previous three issues of Countdown to CARB, click here:
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| Countdown to CARB is brought to you by Timber Products Company and SierraPine. Timber Products' GreenT line of hardwood plywood is CARB-certified and readily available nationwide. All of SierraPine's products are certified to the CARB Phase I or Phase II emission requirements. For more information on Timber Products' and SierraPine's CARB-certified products, visit www.timberproducts.com or www.sierrapine.com. |
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