Closer Alignment Between EPA Composite Wood Product Requirements and CARB
The US Environmental Protection Agency (EPA) published a revision to the Formaldehyde Standards for Composite Wood Products Act on August 21, 2019. The amendments address some technical issues and bring closer alignment with Phase 2 of California’s Airborne Toxic Control Measure (ATCM).
The latest Final Rule includes various important provisions, such as:
• Clarifying the manufactured-by date (including date of import) was June 1, 2018 in accordance with a 2018 court ruling
• Updating the ISO/IEC 17025:2005(E) and ISO/IEC 17011:2004(E) voluntary consensus standards to their 2017 version
• Changing the number of consecutive quality control tests from two to three for the notification of a panel manufacturer exceeding its established Quality Control Limit (QLC) within 72 hours of the time the Third-Party Certifier (TPC) becomes aware of the exceedance (40 CFR §770.7(c)(4)(v)(C))
• Revising the minimum number of quality control tests to be conducted according to the no-added formaldehyde (NAF) two-year limit exemption application from five (5) to 13 (40 CFR §770.17(a)(4))
• Revising the minimum number of quality control tests to be conducted according to the ultra low-emitting formaldehyde (ULEF) two-year exemption or reduced testing application from 10 to 26
• Allowing test results to represent a single chamber value or, if using ASTM D6007-14 (small chamber), the average value of testing nine specimens representing evenly distributed portions of an entire panel (40 CFR §770.20(c)(2)(iv))
• Clarification that the demonstration of equivalence between large and small chambers must be done at least annually or whenever there are significant changes, including equipment, procedure and personnel. It must be between several similar models or size and construction of large and small chambers located in the same TPC laboratory
• Unless TPCs are certifying HWPW in the low range, they may demonstrate equivalence in at least two of the three specified formaldehyde emission ranges as part of the testing requirements (40 CFR §770.20(d)(1)(iv))
• Expanding the options for TPCs and mills in establishing correlation coefficients and ‘r’ values beyond the linear regression model by allowing the ‘cluster approach/point of origin approach’ and the ‘threshold approach’ (40 CFR §770.20(d)(1)(2))
• Clarifying that compliant panels and finished goods must be properly labeled before entering the US
This Final Rule also clarified the abolishment of the requirement for TPCs and mills to demonstrate the correlation between ASTM E1333-14 (large chamber), or upon equivalence ASTM D6007-14 (small chamber), and the mill quality control testing method on an annual basis. The EPA now only requires an initial determination of correlation. After this, the process only needs to be done when there is a significant change in terms of equipment, procedures and/or personnel.
The Final Rule implementing the Formaldehyde Standards for Composite Wood Products Act was issued in December 2016. Its formaldehyde emission standards are identical to those in the California Air Resources Board’s (CARB’s) ATCM Phase 2. The amended compliance date was June 2018.
Both CARB and EPA have provisions relating to a variety of products, including:
• Formaldehyde emission standards for hardwood plywood-composite core (HWPW-CC), hardwood plywood-veneer core (HWPW-VC), particleboards (PBs) and medium-density fiberboards (MDFs)
• Economic operators (panel manufacturers, fabricators, distributors, importers and retailers)
• Third-party certification programs
• Incentives for products manufactured from ultra-low emitting formaldehyde resins (ULEF) and no added-formaldehyde-based resins (NAF)
• Product labeling
• Third-Party Certifiers (TPCs)
US EPA also has provisions for Accreditation Bodies (ABs).
To read the complete Formaldehyde Standards for Composite Wood Products Law, including all amendments, read 40 CFR Part 770. [https://gov.ecfr.io/cgi-bin/text-idx?SID=3342c4de8ecc777250b29218684fb675&mc=true&node=pt40.34.770&rgn=div5#se40.34.770_12]
The most recent Final Rule came into effect on August 21, 2019.
SGS US Formaldehyde Emissions Certification Services
Through a global network of Third-Party Certification (TPC) laboratories, SGS provides the full-range of services, including certification, analytical testing and consultancy, for formaldehyde emissions in composite wood products for California, the US and worldwide markets. Learn more about SGS’s US Formaldehyde Emissions Certification Services. [www.sgs.com/en/consumer-goods-retail/toys-and-juvenile-products/toys/us-formaldehyde-emissions-certification]
SGS SafeGuardS keep you up to date with the latest news and developments in the consumer goods industry. Read the full US EPA Further Aligns Composite Wood Product Requirements with CARB SafeGuardS. [www.sgs.com/en/news/2019/08/safeguards-12419-us-epa-further-aligns-composite-wood-product-requirements-with-carb]
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