CARB COMPLIANCE WORKSHOP

What You Need to Know What You Need to Do
Presented by: Kip Howlett June 5, 2008 Huntsville, Ontario, Canada

CARB COMPLIANCE WORKSHOP

What Everyone Needs to Know
Formaldehyde emission standards Requirements for your industry sector Sell-through provisions Requirements for third-party certification of emissions; exemptions from ATCM  Recordkeeping, product labeling    

CARB COMPLIANCE WORKSHOP
What Everyone Needs to Do
    Comply with emission standards Recordkeeping Labeling Statements of compliance on bill of lading or invoice

CARB COMPLIANCE STANDARDS AND TIMETABLE
Phase 1 and Phase 2 Formaldehyde Emission Standards for Hardwood Plywood (HWPW), Particleboard (PB), and Medium Density Fiberboard (MDF)
Phase 1 (P1) and Phase 2 (P2) Emission Standards (ppm)1

Effective Date 1-1-2009 7-1-2009 1-1-2010 1-1-2011 1-1-2012 7-1-2012
1

HWPWVC P1: 0.08 ----P2: 0.05 -------------

HWPWCC ----P1: 0.08 ------------P2: 0.05

PB P1: 0.18 --------P2: 0.09 ---------

MDF P1: 0.21 --------P2: 0.11 ---------

Thin MDF P1: 0.21 ------------P2: 0.13 -----

Based on the large chamber test method (ASTM E1333-96) in parts per million (ppm). HWPW-VC = veneer core; HWPW-CC = composite core

IMPLEMENTATION DATES
Regulation Driven
 Phase 1 HWPW-VC • January 1, 2009  Phase 1 HWPW-CC • July 1, 2009  Phase 2 HWPW-VC • January 1, 2010  Phase 2 HWPW-CC • July 1, 2012

Customer Driven
 Will some clients want compliant product before the ATCM regulation effective dates?

HARDWOOD PLYWOOD DEFINITION Hardwood plywood includes
 Wall paneling  Industrial panels  Hardwood plywood panels used to make flooring

Hardwood Plywood Does Not Include
 Laminated products  Military specified plywood  Curved plywood

EXEMPTIONS TO ATCM
Composite wood products or finished goods containing CWP manufactured, sold, offered for sale, or supplied for shipment outside California CWP used in manufactured homes subject to the HUD Manufactured Housing Standard

SELL-THROUGH PROVISIONS
Sector Dependent Controversial Statements Made by CARB Enforcement at AHFA Workshop

SELL-THROUGH PROVISIONS
Manufacturers of Hardwood Plywood – 3-Month Sell-Through Period
 Veneer Core manufactured before 1/1/09 that does not comply with Phase 1 • May be sold, supplied or offered for sale by manufacturer until March 31,2009  Veneer core manufactured on or after 1/1/09 must comply with Phase 1  All veneer core used in California must comply with Phase 1 by 3/31/09

SELL-THROUGH PROVISIONS
Manufacturers of Hardwood Plywood
 3-Month sell through applies to composite core hardwood plywood for Phase 1 and Phase 2 based on respective effective dates

Manufacturers of Particleboard and MDF
 Same 3-month sell through periods for Phase 1 and Phase 2 based on effective dates

SELL-THROUGH PROVISIONS
Fabricator Sell-Through Provisions
 Finished goods containing composite wood products “… that does (sic) not comply with the Phase 1and Phase 2 effective dates specified in section 93120.2(a) may be used, sold, supplied, offered for sale by fabricators for up to eighteen months after each of the specified effective dates.”

SELL-THROUGH PROVISIONS
Controversy at AHFA Workshop
 CARB Enforcement Division speaker says Phase 1 sell-through provisions only apply to furniture manufactured before January 1, 2009.  Hypothesis – this interpretation mirrors requirement for all composite wood products manufactured after January 1, 2009 to meet Phase 1 emission limits  Reality – if fabricators can purchase non-compliant board 3-months after effective date, it should be allowed for use in the manufacture of furniture – which then has an 18-month sell-through period  Need interpretation from CARB

SELL-THROUGH PROVISIONS
Distributors
 Composite wood products: 5 months after respective Phase 1 and Phase 2 effective dates  Finished goods containing composite wood products: 18 months after specified effective dates

Importers
 Composite wood products: 3 months  Finished goods: 18 months

SELL-THROUGH PROVISIONS
Retailers
 Composite wood products: 12 months  Finished goods: 18 months

SELL-THROUGH PROVISIONS SUMMARY
CWP Manufacturers Distributors Importers Fabricators Retailers 3 mos 5 mos 3 mos 3 mos 12 mos Finished Goods N/A 18 mos 18 mos 18 mos 18 mos

HARDWOOD PLYWOOD EXEMPTIONS

Military specified plywood Curved plywood Laminated products
 Hardwood plywood manufactured by fabricators  Championed by kitchen cabinet and furniture industries  Competitive disadvantage to hardwood plywood manufacturers

HARDWOOD PLYWOOD EXEMPTIONS

Laminated products
 Definition: Finished good or component part of a finished good made by a fabricator in which a laminate or laminates are affixed to a platform. If the platform consists of a composite wood product, the platform must comply with the applicable emission standards and must be third-party certified  Resulting laminated product does not have to comply with the ATCM emission standards or be third-party certified

HARDWOOD PLYWOOD EXEMPTIONS

Laminated products
 Fabricators manufacturing composite wood products exclusively for use by the fabricator in making finished goods must meet all applicable requirements for a manufacturer (e.g. comply with the ATCM emission limits and be third-party certified) with the exception of product labeling

HARDWOOD PLYWOOD EXEMPTIONS

Laminated Products
 Laminated products replaced Architectural Plywood exemption in previous versions of ATCM  HPVA Technical Committee opposed exemption for AP and laminated products  HPVA comments for almost two years objected to the exemption  May be recognition from CARB that a mistake was made – change now would require a new rulemaking

PRODUCT LABELING
Composite Wood Products
 Manufacturer Name  Product complies with applicable Phase 1 or Phase 2 emission standard or was made using NAF or ULEF resins  Product lot or batch number  ARB assigned number of approved thirdparty certifier (does not apply to manufacturers using ARB approved NAF or ULEF resins)  Statement of compliance on bill of lading or invoice

PRODUCT LABELING
Distributors, Importers
 If composite wood products or finished goods were not modified, no additional labeling required  If composite wood products or finished goods were modified, labeling is the same as required for fabricators

Retailers
 No labeling requirements

PRODUCT LABELING
Fabricators
 Must label all finished goods containing hardwood plywood, PB, or MDF to be sold or supplied to California  Label must be applied as a stamp, tag, sticker, or bar code on every finished good produced or on every box containing the finished good

PRODUCT LABELING
Fabricators
 Label must include • Fabricator’s name • Date finished good was produced • Marking to denote finished good manufactured with composite wood products compliant with Phase 1 or Phase 2, or manufactured with CARB approved NAF or ULEF resins • Statement of compliance to applicable emission standards on bill of lading or invoice

RECORDKEEPING
Composite Wood Products
 Starting January 1, 2009, must keep records of all quality assurance emissions test data for each product  Manufacturers using CARB approved NAF and ULEF resins must keep records documenting ARB approval  Records must be kept in hard copy or electronic form for two years

RECORDKEEPING
Composite Wood Products
 Records kept for two years must include: • Tracking information to allow a product to be traced to a specific lot or batch • Product information • Purchaser information • Transporter information • Identification of ARB approved TPC • Disposition of non-complying lots

RECORDKEEPING
Distributors, Importers, Fabricators, Retailers
 Date of purchase  Supplier  Document precautions ensuring compliant materials were purchased or sold  Electronic or hard copy for at least two years  Available to ARB or local air district personnel on request

QUALITY ASSURANCE FOR MANUFACTURERS
QC Testing Objective
 Quality control testing shall be conducted and analyzed within a period of time specified in the Quality Control Manual to avoid shipping of non-complying lots  Failure of a quarterly primary or secondary test is indicative of a failed QC program leading to a “red tag” on non-complying lots and a recall of all production from the date the quarterly test samples were selected

Small Scale Quality Control Tests in Plant

Non-Complying Lots
 Any lot with a test value that exceeds the applicable standard  Must be isolated from other certified lots  May be re-certified by treating with scavenger or use of other means to reduce formaldehyde and re-testing  If manufacturer does not re-certify, lot may not be labeled for sale in California  If already labeled, label must be removed

Small Scale Quality Control Tests in Plant

Non-Complying Lots
 Small Scale Retesting • At least three panels from three separate bundles • Each panel shall be tested using plant’s small scale quality control test • Average of three samples must test below the quality control limit • If lot can not be recertified, certifier must be notified promptly in writing

Small Scale Quality Control Tests in Plant

Plant Reporting
 Each manufacturer must maintain product data reports for each plant, production line, and product type  Copies must be submitted to certifier at least monthly  Report must include • Quality control limit • Results of quality control tests • Retest values

Small Scale Quality Control Tests in Plant
Recordkeeping
 Complete records must be kept documenting: • Small scale test results with testing frequency • Production sequence • Changes in resin percentage • Increases in u-f mole ratio • Changes in press time more than 20% • Testing of QC employees • Disposition of non-conforming products • Records must be maintained at least 2 years

Recommendations
GET A COPY OF THE REGULATION
http://www.arb.ca.gov/regact/2007/compwood07/compwood07.htm

For Further Information Gary D. Gramp gramp@hpva.org 703-435-2900, Ext. 115

THANK YOU!

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