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Wood industry sectors face a sorting-out phase following the April 18, 2008 final approval of the California Air Resources Board's (CARB) composite wood ACTM (Air Toxics Control Measure), which set formaldehyde emissions limits.
As the rule enters the enforcement phase, it remains a major focus for manufacturers and at trade association seminars and annual meetings.
The focus now is on testing and third-party certification.
Industry organizations have been incorporating CARB limits in their environmental programs and providing members with detailed information on compliance requirements.
CARB's own outreach efforts include regular Web updates, plans for a summer trip to China, targeted mailings and outreach to overseas trade associations, and ongoing presentations by CARB technical representatives at industry trade conferences.
As previously reported in Wood Digest (June 2007 and Feb. 2008), the rule imposes a two-phase compliance schedule ending in 2012 for urea formaldehyde (UF) emissions limits from composite wood products. It allows exemptions for products using NAF (no added formaldehyde) and ULEF (ultra-low-emitting formaldehyde) resins.
CARB adopted a flexible test protocol allowing for small chamber as well as large chamber testing. It is now approving third-party certifiers (TPC).
As of late May, CARB had approved the Composite Panel Association (CPA) and Professional Services Industries, Inc. (PSI) as TPCs. Over 15 U.S., European and Asian certifier organizations are in the process of applying for approval. There could be a half dozen approved by this month.
"The TPCs are the last element we have to put in place," says Jim Aguila, manager of CARB's Technical Services Section.
CARB will be doing its own testing toward working out the sample handling analysis and testing protocols, using a small chamber. It has a contract with the state's Department of Public Health for using its large chamber.
Industry concerns include testing methods and the workability of enforcement measures, especially with regard to finished products. The ATCM adds yet another certification and labeling requirement to the growing forest of government regulations, building codes, environmental organization programs, and other third-party certifications, international as well as domestic. Chain of custody documentation is another concern.
In addition to trade association attention to the rule, there has been some discussion of potential adoption of the CARB ATCM by other states and the federal government. (See box, p. 32)
"Federalizing" CARB, says CPA director of environmental affairs John Bradfield, would not have a significant practical impact for CPA members. CPA's EPP (Environmentally Preferable Product) adopted CARB Phase 1 limits as of April 1, 2008. CPA's TPC facility expects to certify 55 North American facilities this year.
Panel and board makers are not yet ready for Phase 2 compliance, "but they expect to be by the effective compliance date," Bradfield says.
Downstream customers are calling board makers asking for Phase 1-compliant board. There appears to be little customer concern at this point over Phase 2 compliance, says Chris Leffel, Sierra Pine director of sales and marketing.
Industry awareness is clear and increasing. Compared to the excitement generated by CARB over the past year, Italian-based 3B S.p.A found little interest or awareness on formaldehyde when it first started selling in the United States over a decade ago.
3B's MDF doors were compliant with CARB, says Donn Wilber, 3B USA sales and marketing director, since the company had to meet Europe's E1 standard by 1992.
"We didn't realize it was important to (U.S. customers), and they didn't realize they were buying it," Wilber says. 3B's Acrilux and Round lines are also certified to Japanese standards.
Testing, testing
A finished products working group, consisting of representatives from CARB, trade associations and other interested groups, will continue the cooperative process between industry and government that typified development of the ATCM.
Finished goods must use certified board, and the testing methods and costs are perhaps the most problematic part of the rule for fabricators and finished goods manufacturers.
"Using noncertified board won't fly because users may customize it, perhaps by drilling a hole," BIFMA's Miller says. "Who's going to be responsible for that?"
"We have to get to the panel inside. We have to hold the panel makers to the highest standards," says Aguila.
Even with laminated and edgebanded board, "you get emissions from the edges. The edges are not perfect seals, and they're the highest impact areas," he says.
This is where supply chain management enters the picture.
"Fabricators must take the additional step of using reasonable and prudent precautions," Aguila says.
"We want to make sure there is an open process for manufacturers — a clearly understood testing scenario," says Brad Miller, BIFMA International director of communications. "We have some expertise in furniture emissions standards, and we think we can help the Air Resources Board understand the processes involved in bringing product to market."
At the same time, says Kip Howlett, president of the Hardwood Plywood & Veneer Association (HPVA), "there are critical ambiguities in the test methods that need to be resolved." These include preconditioning questions such as the allowable air changes in the preconditioning room. "This needs to be specified," he says.
Global trade means attention to global environmental regulations and standards. European standards monitor content, while North American standards measure emissions, Leffel says. "E1 is not as stringent."
Some correlations have been done that give an approximation of what emissions might be based on content. "It's a pretty good estimate, but it's not a perfect correlation," says Leffel.
Neither are the testing methods. The North American ASTM E-1333 large chamber test, European DIN E1, and Japanese F 3-star and F 4-star are not readily comparable.
The International Wood Products Association (IWPA) is concerned about appropriateness of the third-party certification requirement, chain of custody documentation, and the ATCM's impact on the competitiveness of IWPA products in the U.S. market.
Representing importers, IWPA looks only to U.S. standards. "Our issue is you have a unique standard for CARB that doesn't work for Oregon," says IWPA executive vice president Brent McClendon. "You need to meet the needs of the marketplace, whether they're specific customer needs or a regulatory standard. It's the importer's job to select the product that meet those specs. It's a quality assurance role."
Ongoing concerns
"I remain concerned that CARB will not come up with a method to enforce this rule, particularly on finished products," Leffel says.
"California did a very good job, and the industry did a very good job in working with the state," Leffel says. "But if any other state or the federal government wants to adopt this, they should wait and see how it plays out."
Sierra Pine already meets CARB Phase 1 particleboard levels using urea formaldehyde. MDF is more difficult, but Sierra Pine expects to meet the Jan. 1, 2009 deadline.
Phase 2 deadlines will also be easier with particleboard than with MDF.
"At this point, without an alterative resin system, I don't see how we'll meet Phase 2," Leffel says. "The regulation is technology-forcing, but it will be more expensive."
ULEF (ultra low-emitting formaldehyde) and NAF (no added formaldehyde) are available today, but at higher costs.
Sierra Pine's Arreis (MDF), Medite II (MDF) and Encore (PB) are formaldehyde-free.
"We're using all technologies, but these are significantly more expensive and the downstream market is going to be charging a higher price to cover the extra costs," Leffel says.
Arreis is the most affordable UF-free board, with a slight premium over UF product.
At the same time, Leffel says, affordability is relative. "This will increase costs across the board," he says.
author: By Lisa Harbatkin