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Formaldehyde Emissions Regulations (CARB/EPA Rule)

For Composite Wood Products
Stanley Mathuram, P.E., Vice President, Corporate Salesphone icon616.299.1073 Email

Reduce risk and assure your customers that your composite wood products fully comply with the California Air Resources Board (CARB) Airborne Toxic Control Measure (ATCM 93120) and the EPA Formaldehyde Rule for formaldehyde emissions by the June 1, 2018 deadline. Producers selling hardwood plywood (veneer or composite core), particleboard, and medium density fiberboard (MDF) products in the United States must comply by the new deadline set for June 1, 2018. SCS is an approved Third Party Certifier (TPC) for both CARB ATCM 93120 and TSCA Title VI regulatory requirements. SCS meets EPA regulatory requirements to certify composite wood products under Toxics Substance Control Act (TSCA) Title VI.

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EPA Formaldehyde Rule

Important timeline and dates:

  • By June 1, 2018, regulated composite wood panels and finished products containing such composite wood panels that are manufactured (in the United States) or imported (into the United States) must be certified as compliant with either the TSCA Title VI or the California Air Resources Board (CARB) Airborne Toxic Control Measures (ATCM) Phase II emission standards, which are set at identical levels, by a third-party certifier (TPC) approved by CARB and recognized by EPA. Previously, these products were required to be TSCA Title VI compliant by December 12, 2018.
  • Until March 22, 2019, regulated products certified as compliant with the CARB ATCM Phase II emission standards must be labeled as compliant with either the TSCA Title VI or the CARB ATCM Phase II emission standards.  Regulated products manufactured in or imported into the United States after March 22, 2019 may not rely on the CARB reciprocity of 40 CFR 770.15(e) and must be certified and labeled as TSCA Title VI compliant by an EPA TSCA Title VI TPC with all of the required accreditations.
  • After March 22, 2019, CARB-approved TPCs must comply with additional accreditation requirements in order to remain recognized as an EPA TSCA Title VI TPC and to continue certifying products as TSCA Title VI compliant.
Program Details
Eligibility

This program applies to producers of medium density fiberboard (MDF), particle board (PB), and hardwood plywood (HWP), including veneer and composite core.

Program Criteria

Formaldehyde levels in certified products must fall within established limits set by the state of California for each type of product. For more information about the regulation, including updates and advisories, see:

http://www.arb.ca.gov/toxics/compwood/compwood.htm

美国加州有毒有害气体控制和管理办法

Process
  1. Apply for Certification

    Complete and submit an SCS Application Form. SCS scopes the project based on information provided in the application and prepares a proposal for your approval with a suggested timeline and quote. Once you approve the proposal, you sign a Work Order.  An SCS account manager is be assigned to guide you through the certification process.

  2. Data Collection

    An SCS technical coordinator helps you assemble preliminary data that will be submitted to SCS. SCS reviews the product data, corporate documentation, manufacturing process, product formulation, testing, etc., and assesses your readiness for an audit. Once sufficient data is collected, an auditor is assigned.

  3. On-site Audit

    The auditor conducts an on-site audit to evaluate your data. The auditor interacts with your technical staff to clarify and obtain any additional information that might prove essential to reaching an accurate supportable evaluation.

  4. Draft Assessment Report

    The auditor writes a draft assessment report that details the findings of the audit, which includes data analysis, non-conformities, and opportunities for improvement.

  5. Internal peer review

    A second qualified SCS representative reviews the report, making any necessary corrections or changes before the report is sent to the client.

  6. Corrective Actions

    You respond to any non-conformities with a Corrective Action Plan. You may also make comments and responses to the information contained in the report and the conclusions drawn by the auditor.

  7. Certification Decision

    SCS conducts a final technical review of the assessment report and makes the final certification decision. If certification is granted, SCS issues the certificate and final report to your facility or operation. Once certified, your company is listed in the Green Products Certificate Database on the SCS website.

  8. Certification Maintenance and Renewal

    Depending on the certification, SCS requires annual audits to maintain your certification and support continual improvement.

FAQs

The State of California Air Resources Board provides an extensive list of questions frequently asked about the implementation of this regulation. Some of these questions and answers are excerpted below. For the full set, visit: http://www.arb.ca.gov/toxics/compwood/implementation/faq.htm

What composite wood products fall under the airborne toxic control measure (ATCM)?

The ATCM applies to all hardwood plywood (HWPW), particleboard (PB), and medium density fiberboard (MDF), including thin MDF (≤ 8 mm), and finished goods that contain these products, that are sold, offered for sale, supplied, used, or manufactured for sale in California.

What specific products are not covered by the ATCM?

Materials that are not covered by the ATCM include, but are not limited to hardboard, natural wood, and certified structural plywood, certified structural panels, structural composite lumber, oriented strand board, glue laminated timber, prefabricated wood I-joist, finger jointed lumber, or "composite wood products" used inside of new vehicles, rail cars, boats, aerospace craft or aircraft (please also refer to question #23).

What are examples of finished goods?

Finished goods mean any good or product other than a panel, containing HWPW, PB, and MDF. Finished goods include, but are not limited to furniture, cabinets, shelving, countertops, flooring, moldings, caskets, base boards, rosettes, corbels, etc.

Who does the ATCM apply to?

The ATCM applies to manufacturers, distributors, importers, fabricators, and retailers of the products described in question 1, as well as third party certifiers of manufacturers.

Does the ATCM apply to blockboard?

No, blockboard is not covered by the ATCM since it is not included in the definition of HWPW.

Does the ATCM apply to molded pallet blocks?

Molded pallet blocks that are made in individual molds and made specifically as molded pallet components are exempt for the ATCM. If in a given manufacturing process no flat panels are made or used, and if the resulting molded pallet block products have a very specific purpose, then molded pallet block products would not be subject to the ATCM.

Does SCS provide certification support?

SCS provides ongoing program support, including on-going staff assistance, marketing and promotional support, and information about new or revised requirements. Certified clients will receive information about creating batch-specific Lot Labels for on-product use.

For immediate service:

Stanley Mathuram, P.E., Vice President, Corporate Sales phone icon 616.299.1073 Email Stanley

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