LOWER EMISSION STANDARDS BEGIN IN 2009

Retailers, suppliers, as well as manufacturers, will need to comply with the following emission standards:

Phase 1 Emission Standards (in parts per million (ppm))
Effective Date	Hardwood plywood: veneer core	Hardwood plywood: composite core	Particle Board	Medium Density Fiberboard	Thin Medium Density Fiberboard
January 2009	0.08ppm	- - -	0.18 ppm	0.21 ppm	0.21 ppm
July 2009	- - -	0.08ppm	- - -	- - -	- - -
Phase 2 Emission Standards (in parts per million (ppm))
January 2011	0.05 ppm	- - -	0.09 ppm	0.11 ppm	- - -
January 2012	- - -	- - -	- - -	- - -	0.13 ppm
July 2012	- - -	0.05 ppm	- - -	- - -	- - -

Who Needs to Comply and How

Retailers will be required to keep a RPP (Reasonable Prudent Precautions) chain (i.e., Chain of Custody) whereby they provide the suppliers of finished products which contain ANY part composed of composite wood, copies of the regulation, along with a request to be supplied low or no formaldehyde resin products. The retailer must keep copies of these letters to current suppliers on file.

Manufacturers: Along the same line, fabricators of products which contain ANY part that is composed of composite wood will also be required to keep a RPP chain, whereby they provide the suppliers of raw composite wood material, copies of the regulation, along with a request to be supplied low or no formaldehyde resin composite wood. The fabricator must keep copies of these letters to current suppliers of raw material on file.

Suppliers of raw composite wood materials will be required to have in place a system entitled BACT (Best Available Control Technology) which is similar to the RPP chain described above. Suppliers of raw composite wood material must show that they are using BACT to produce their product(s). That is, if their materials are going to be used in product(s) destined for California.

Testing Requirements Still in Development

The methods to test finished products have not been officially finalized. However, preliminary information indicates that ASTM D6007 will be used in the audit process of retail stores. If during this audit process, high levels of formaldehyde are recorded (i.e., close to or above the limits set by the standard) the product will then be subjected to ASTM E1333.

ASTM D6007 is a quantitative method for determining the level of formaldehyde release to the atmosphere from wood utilizing a small chamber. ASTM E1333 is similar; however, this standard incorporates the use of a large chamber, and yields a higher level of accuracy.

The delay in finalizing testing for finished products revolves around the method of deconstruction of finished products prior to testing. CARB is currently performing Gas Chromatography studies on two types of finished products, laminated on one side and fully laminated or laminated on all sides, as well as on unfinished products to determine if and how “deconstruction” of a finished product or panel will effect formaldehyde emissions. CARB officials have stated that testing methods will be finalized and made available sometime in early 2008.

Comprehensive Services Available

Bureau Veritas is committed to offering services to assist you in meeting the requirements of this upcoming Regulation. While test methods are being finalized, we are monitoring the situation and preparing to implement the appropriate test methodologies once they become available. We will keep you informed as new developments occur. 
 
In the meantime, we can provide you with customized training sessions to better understand how the regulations will affect you and how to implement an RPP chain. Sharing information early with suppliers and partners in your supply chain can help increase the likelihood that future products will comply with the upcoming Regulation.

AFFECTED PRODUCTS

California’s Regulations focus on three types of composite wood products: hardwood plywood, particleboard, and medium density fiberboard (MDF). These products are used to make furniture, cabinets, shelving, countertops, flooring, and moldings in homes. All wood has some naturally occurring formaldehyde. However, more formaldehyde is added to composite wood in the form of certain resins that are used to bind wood particles together.

PENALITES AND VIOLATIONS

Violations of the Regulation will be handled on a case-by-case basis and no information is being provided about monetary penalties. CARB has stated that the release of the penalties in terms of “how much it will cost for violations” allows retailers/suppliers to weigh the costs of penalties against the cost of conforming to the regulation, and sets up a “gambling scenario” (e.g., we are going to sell X units with a profit of X dollars, if we get caught, it will cost us X dollars vs. it will cost us X dollars to comply with the regulation).

Contact Information
Please contact your client services representative or Rufus Moberly via email rufus.moberly@us.bureauveritas.com.

 Printer-friendly Bulletin

Preview

Download

Click here for a complete list of our Regulatory Bulletins

Bureau Veritas Consumer Products Services, Inc. (“BVCPS”) provides the information in this client bulletin as a resource of general information.  It does not replace any applicable legal or regulatory requirements and is provided “as is.”  BVCPS will not be liable for any indirect, special, punitive, consequential or other damages (including without limitation lost profits) of any kind in connection with this client bulletin.  BVCPS DISCLAIMS ALL REPRESENTATIONS AND WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, IN CONNECTION WITH THIS CLIENT BULLETIN.

Copyright © 2007 Bureau Veritas Consumer Products Services, Inc.  All Rights Reserved