Monday, September 23, 2013

EPA Title VI Regulations for Formaldehyde: Traceability Matters

While in my local hardware store picking up some essentials, I saw cabinet kits on a shelf. Out of curiosity, and due to the nature of my job, I decided to check out the formaldehyde labeling on the product. Since the proposed EPA regulations for formaldehyde emissions from composite wood products (Toxic Substance Control Act Title VI) haven’t yet been implemented, and the California Air Resource Board (CARB) CA93120 requirements don’t apply here in the Midwest, I wasn’t sure what to expect. Still, I wanted to see if the cabinet kits met any specific formaldehyde emissions requirements. The packaging didn’t have any labeling. The individual particleboard and medium-density fiberboard parts included markings, but not related to formaldehyde. 

One of the questions I’m hearing related to the regulations is “What’s my responsibility as an importer, distributer, fabricator or retailer to show I’m meeting the requirements of the TSCA Title VI?”
Importers, distributers, fabricators and retailers are the guys who don’t make the composite wood panels falling under the TSCA Title VI, but they handle them. The panels come in their doors and then are resold, sometimes as panels, sometimes cut down into smaller parts and sometimes after being assembled into finished goods like cabinets or furniture.
These types of entities have similar responsibilities with respect to meeting the documentation requirements of the TSCA Title VI. In simple terms, they need to show that any product containing the composite wood leaving their facility was manufactured with compliant material.
From a quality system standpoint, I’m talking about traceability. Traceability is being able to track a finished product back to the purchasing, manufacturing and quality control records related to its production.
For example: We work with a cabinet manufacturer who has an inspection checklist for incoming materials. When checking in material, his receiver ensures the packing slip matches the purchase order, as well as the material’s quality manual. The label on the material should identify the producer, the date of production and the company that tested the material for quality compliance. The inspection checklist then goes to the quality manager, who reviews and files it. 
The label on the finished cabinet includes the manufacturer’s name, the production date and a statement of compliance. The production date identifies which batch of material was used and the receiving checklist documenting its compliance.
If someone ever questioned this cabinet manufacturer about the product’s formaldehyde emissions, he could demonstrate that a specific cabinet was manufactured from a specific batch of material produced by a specific panel manufacturer on a specific date. Additionally, he can show the material appeared compliant when received. Now it’s the panel manufacturer’s responsibility to produce their records documenting the material’s compliance.
So, it all comes down to due diligence. Did the cabinet manufacturer do everything he needed to do to ensure he was complying with the law? The particular cabinet manufacturer highlighted in this example also performs formaldehyde emissions testing. Not on every batch, but enough to keep his suppliers honest. It’s not a program requirement; he does it to increase his comfort level.
Before the TSCA Title VI regulations are implemented, you’ll want to evaluate your quality system to determine your level of traceability. 
Remember: You have until Oct. 9 to submit your comments on docket EPA-HQ-OPPT-2012-001 at www.regulations.gov. Let your voice be heard!

NTA will be participating in the comment process and we’ll continue to monitor the impact of the regulations on our clients. Look for additional information regarding the EPA formaldehyde regulations in the October issue of our e-newsletter.

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