Thursday, October 13, 2016

Complying with the new Federal Formaldehyde Emission Standards

The new EPA Formaldehyde Emission Standards program looks a lot like the well-known CARB program  (California Air Resources Board). The CARB program was one of the first successful programs that aims to reduce exposure to Formaldehyde emissions. First approved by ARB in 2007, the first emission standards were implanted on 1/1/2009. In the past seven years, much has been learned from their program, and the EPA built on their experiences for the new Federal program.

The new rules will apply to any composite wood product and component parts, or finished goods, sold in the U.S. This mean that ANY composite wood product that is sold, supplied, offered for sale, manufactured or imported must be labeled as TSCA Title VI compliant. The italics on ‘supplied’ and ‘imported’ are intentional, to emphasize it is not just manufacturers who must comply, but distributors, importers, fabricators and retailers.

How can a distributor, importer, fabricator or retailer ensure compliance when they do not produce the material?

The regulation contains many quality system requirements including internal QC test frequency, guidelines for establishing Quality Control Limits (QCL), controls for materials and processes which might affect formaldehyde emissions, reporting requirements, documentation requirements and labeling requirements among others. Like the CARB program, the quality system will be monitored by a Third Party (TPC) on a quarterly basis. This will include quarterly testing.

The rule requires panels or bundles of panels that are sold, supplied, or offered for sale in the U.S. must be labeled with the panel producer’s name, the lot number, the number of the EPA TSCA Title VI TPC, and a statement that the products are TSCA Title VI certified. If a composite wood panel is not individually labeled, the panel producer, importer, distributor, fabricator, or retailer must have a method sufficient to identify the supplier of the panel and linking the information on the label to the products. They need to meet these documentation requirements so that a finished good can be traced back to the mill source of the material. NTA can help you to verify that your quality system is meeting the requirements of 40 CFR 770 and we can help you set up a Supplier Verification testing program to monitor the materials you receive, provide evidence of your compliance and limit your liability to the public at large. 

Watch NTA perform the ASTM E1333 Large Chamber Formaldehyde Test

Get started today on your Supplier Verification Program, before the deadline. Contact NTA to discuss a customized Supplier Verification that will suit you – today!

No comments:

Post a Comment

Note: Only a member of this blog may post a comment.