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 HWPW- HWPW- PB MDF Thin MDF

Date VC CC
1-1-2009 P1: 0.08 ----- P1: 0.18 P1: 0.21 P1: 0.21
7-1-2009 ----- P1: 0.08 ----- ----- -----
1-1-2010 P2: 0.05 ----- ----- ----- -----
1-1-2011 ----- ----- P2: 0.09 P2: 0.11 -----
1-1-2012 ----- ----- ----- ----- P2: 0.13
7-1-2012 ----- P2: 0.05 ----- ----- -----
Based on the large chamber test method (ASTM E1333-96) in parts per million
1

(ppm).
HWPW-VC = veneer core; HWPW-CC = composite core
 IMPLEMENTATION DATES
Regulation Driven Customer Driven
 Phase 1 HWPW-VC  Will some clients want
• January 1, 2009 compliant product
 Phase 1 HWPW-CC before the ATCM
regulation effective
• July 1, 2009
dates?

 Phase 2 HWPW-VC
• January 1, 2010
 Phase 2 HWPW-CC
• July 1, 2012
 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 Finished Goods

Manufacturers 3 mos N/A

Distributors 5 mos 18 mos

Importers 3 mos 18 mos

Fabricators 3 mos 18 mos

Retailers 12 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 third-
party 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!