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SAFEGUARDS | Hardlines NO. 033/17

SafeGuardS Hardwood floor

The US EPA has published a guideline to assist manufacturers/mills to comply with the nation’s law on formaldehyde emissions in composite wood.

In July 2010,  we informed [1] you that President Obama signed ‘The Formaldehyde Standards for Composite Wood Products Act’, into law. This piece of landmark legislation added Title VI to the Toxic Substances Control Act (TSCA) and directed the US Environmental Protection Agency (EPA) to finalize a rule on implementing the law.

In December 2016, the EPA published the Final Rule in the Federal Register. This Rule [2] includes provisions relating to, among others, formaldehyde emission standards in hardwood plywood veneer core or composite core (HWPW-VC or CC), particleboards (PBs) and medium-density fiberboards (MDFs), third-party certification programs, incentives for products manufactured from ultra low-emitting formaldehyde resins (ULEF) and no added-formaldehyde-based resins (NAF), product labeling, Accreditation Bodies (ABs) and Third-Party Certifiers (TPCs). The formaldehyde emission standards are identical to those in Phase 2 of the Air Toxic Control Measure (ATCM) to control formaldehyde emissions under the California Air Resources Board (CARB) and will become effective on December 12, 2017.

In January 2017, the EPA published a guideline to help panel manufacturers (mills) [3] comply with the Final Rule. This guide contains a number of important provisions, including:

  • The relationship between EPA, CARB, CARB-approved TPCs, EPA-recognized ABs, EPA-recognized TPCs and economic operators

  • A list of exemptions

  • Incentives for ULEA resins or NAF-based resins used in composite wood products

  • Product testing requirements

  • A list of approved quality control test methods demonstrating correlation to ASTM E1333-10. These are ASTM D5582-00, ASTM D6007-02, EN 717-2 (Gas Analysis Method), Dynamic Micro Chamber (DMC) – 2007 or 2012 Georgia Pacific User’s Manual, EN 120:1992 (Perforator Method) and JIS 1460:2012 (24-hour Desiccator Method)

  • TPCs and Third-Party Certification requirements

  • Reporting requirements for panel manufacturers

  • Developing quality control manuals and generating monthly product data reports

  • Record keeping and product labeling

  • Enforcement action against violators, including penalties of up to USD 37,500 per violation per day.

It is important to note that the regulations require quality control testing and quarterly testing; the latter of which is conducted by an EPA-recognized TPC. It is also noteworthy that products certified by a CARB-approved TPC are also considered certified under TSCA Title VI, the federal law for formaldehyde emissions in composite wood, until December 12, 2018.

Highlights of the guideline for mills/panel manufacturers relating to formaldehyde emission standards and quality control testing frequency requirements are summarized in Table 1.

Small Entity Compliance, Guide for Mills
Formaldehyde Emissions Standards for Composite Wood Products, Title VI of the TSCA
US EPA, January 2017
Composite Wood Emissions Requirement Quality Control Testing Frequency
MDF  ≤ 0.11 ppm Once per shift (8 or 12h ± 1h of production) for each production line for each product type
Thin-MDF  ≤ 0.13 ppm
PB  ≤ 0.09 ppm
HWPW-VC  ≤ 0.05 ppm
  • At least 1 test/week/product type if weekly production is > 100,000 ft² and < 200,000 ft²
  • At least 2 tests/week/product type if weekly production is ≥ 200,000 ft² and < 400,000 ft²
  • At least 4 tests/week/product type if weekly production is ≥ 400,000 ft²
  • At least 1 test/100,000 ft² for each product type if weekly production is ≤ 100,000 ft² but > 100,000 ft² per month otherwise 1 test/product type every month that it is produced if product type is < 100,000 ft².
HWPW-CC  ≤ 0.05 ppm
Effective date = December 12, 2017

Table 1. Guide for Mills, h = hour, ft = foot

SGS will follow up and inform interested parties as developments on formaldehyde emissions in composite wood products under CARB and other legislation occur. Throughout our global network of laboratories (Hong Kong, Guangzhou, Shanghai, Taiwan), we are able to provide a range of services, including analytical testing and expert consultation related to the emission of formaldehyde in composite wood products destined for California, the US and International markets. Please do not hesitate to contact us for further information or visit our website.

For enquiries, please contact:

Hingwo Tsang
Global Hardlines Information and Innovation Manager
t: +852 2774 7420

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