One of my favorite books
growing up was Douglas Adams’ The Hitchhiker’s Guide to the Galaxy with its iconic “Don’t Panic” logo on
the cover. I’m going to use that as my mantra when addressing the EPA’s Title
VI regulations regarding formaldehyde emissions.
At the end of May, the EPA
released its proposed regulations for how the Toxic
Substance Control Act (TSCA) Title VI program will work. The EPA program is
intended to mirror the California Air Resources Board (CARB) CA93120 program, which regulates formaldehyde
emissions from composite wood products, including hardwood plywood (HWPW),
medium-density fiberboard (MDF) and particleboard (PB). The CARB program
applies to manufacturers, distributors, importers, fabricators, retailers and
third-party certifiers of composite wood products and finished goods that
contain composite wood products destined for the California market.
I believe the major differences
between the two programs fall into these three categories:
1.
Materials required for qualification
2.
Quality system requirements
3.
Administration
In this blog, I’m going to
focus on the EPA’s definition of a laminated product. Section 40 CFR 770.3 of the
proposed regulations defines a laminated product as a product in which a wood
or woody grass veneer is affixed to a PB platform, an MDF platform or a veneer
core platform. This is significant because a company that purchases HWPW, PB or
MDF and then proceeds to laminate wood veneers onto that product is now a
“manufacturer” and needs certification to the Title VI requirements.
The question I’m hearing most from
our clients is: “What sort of laminate materials fit into this category?” The
background material provided with the release of the regulations explains that
the EPA is proposing to exempt some, but not all, laminated products. The EPA
has data related to vinyl, paper, melamine and polyethylene laminates that
justifies their exemption from the regulations. They do not have data for wood
veneer laminates. In fact, except for one section on engineered veneers, the
background documentation discusses wood veneers. So the question remains: Does
laminating products, like applying Formica to particleboard to create a
countertop, make you a plywood manufacturer who’s subject to the new
regulations?
The EPA has requested that
public comments related to their regulations be submitted by Sept. 9, 2013, on
docket EPA-HQ-OPPT-2012-001 at www.regulations.gov. My key takeaway is “Don’t
panic.” Instead, submit your comments to the EPA and provide them with the
necessary justification to exempt additional materials. Even if a specific
material is not exempted, there will be options under the “no-added
formaldehyde (NAF)” section of the program.
NTA will be participating in
the comment process and we’ll continue to monitor the impact of the regulations
on our clients. Keep visiting this site for my future blogs regarding the EPA
formaldehyde regulations.
UPDATE: August 21, 2013
The U.S. Environmental Protection Agency is extending the public comment periods for two proposed regulations that implement the Formaldehyde Standards for Composite Wood Products Act, or Title VI of the Toxic Substances Control Act. Both proposed rules initially published on June 10, 2013. The first notice extends the comment period for the Formaldehyde; Third-Party Certification Framework for the Formaldehyde Standards for Composite Wood Products proposal from August 26, 2013 to September 25, 2013. The second notice extends the comment period for the Formaldehyde Emissions Standards for Composite Wood Products proposal from September 9, 2013 to October 9, 2013.
The U.S. Environmental Protection Agency is extending the public comment periods for two proposed regulations that implement the Formaldehyde Standards for Composite Wood Products Act, or Title VI of the Toxic Substances Control Act. Both proposed rules initially published on June 10, 2013. The first notice extends the comment period for the Formaldehyde; Third-Party Certification Framework for the Formaldehyde Standards for Composite Wood Products proposal from August 26, 2013 to September 25, 2013. The second notice extends the comment period for the Formaldehyde Emissions Standards for Composite Wood Products proposal from September 9, 2013 to October 9, 2013.
The climate box test method for formaldehyde release is commonly used in foreign countries to detect formaldehyde emissions, it’s characteristics is to simulate the indoor climate environment, and the test result is closer to the actual situation. Due to its true, reliable and stable characteristics, it is widely used in certification, third-party testing, and quality control. It might provide you with some help.
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